Defendant,
Civil Action No. 4:10-cv-01210
v.s
Richard J. Kraniak and Roger Kazanowski, Defendants/Counterclaim Plaintiffs,
v.s
Ira Goldknopf, Helen Park, Thomas Waite, and John Ginzler, Third Party Defendants.
JOINT STIPULATION OF DISMISSAL WITH PREJUDICE
COME NOW, Power3 Medical Products, Inc., Ira Goldknopf, Helen Park, Thomas Waite, John Ginzler, Richard J. Kraniak and Roger Kazanowski (collectively the “Parties”) and respectfully file this Joint Stipulation of Dismissal with Prejudice (“Stipulation”) pursuant to FED. R. CIV. P. 41(a)(2), and would respectfully show the Court as follows:
1. The Parties have negotiated and agreed upon terms by which to settle the claims of each of them in the above styled action (the “Litigation”).
2. As a condition of the Settlement Agreement and Full and Final Mutual Release (the “Settlement Agreement”), executed by the Parties and effective as of October 31, 2011, the Parties hereby file this Stipulation.
3. The Parties respectfully request the Court grant this Motion and enter the attached (Proposed) Order of Dismissal with Prejudice so as to effectuate their Settlement Agreement.
Case 4:10-cv-01210 Document 107
Filed in TXSD on 11/07/11 Page 2 of 2
November 7, 2011
THE TAYLOR LAW OFFICES, P.C.
Respectfully submitted,
SPENCER CRAIN CUBBAGE HEALY & MCNAMARA, P.L.L.C.
By: /s/ Richard P. Martini _ Richard P. Martini
Texas State Bar: 13144690
1177 West Loop South, Suite 1300 Houston, TX 77027
Tel: 713.375.2450
Fax: 713.375.2499 RMartini@spencercrain.com
COUNSEL FOR PLAINTIFF POWER3 MEDICAL PRODUCTS, INC. AND THIRD-PARTY DEFENDANTS IRA GOLDKNOPF, HELEN PARK AND THOMAS WAITE
By: /s/ Thomas L. Taylor, III Thomas L. Taylor III
Texas State Bar: 19733700
4550 Post Oak Place Drive, Suite 241 Houston, Texas 77027
Tel: 713.626.5300
Fax: 713.402.6154 taylor@tltaylorlaw.com
COUNSEL FOR DEFENDANTS RICHARD J. KRANIAK AND ROGER KAZANOWSKI
LAPIN & LANDA, L.L.P.
By: /s/ Robert E. Lapin ____ Robert E. Lapin
Texas State Bar: 11945050
500 Jefferson St., Suite 2000 Houston, Texas 77002-7371 Tel: 713.756.3232
Fax: 713.654.8704 blapin@lapinlanda.com
COUNSEL FOR THIRD-PARTY DEFENDANT JOHN GINZLER
Filed under: Uncategorized
