UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
December 4, 2009
LORENA S. ALVARADO, A MINOR, BY AND THROUGH HER GUARDIAN AD LITEM LORENA ALVARADO, PLAINTIFF,
UNITED STATES OF AMERICA, DEFENDANT.
UNITED STATES OF AMERICA, THIRD-PARTY PLAINTIFF,
CHILDREN'S HOSPITAL CENTRAL CALIFORNIA, JOHN E. DINSMORE, MD, DAVID HODGE, MD, AND JILL GHANBARIAN, FNP, THIRD-PARTY DEFENDANTS.
The opinion of the court was delivered by: Oliver W. Wanger United States District Judge
STIPULATION RE DISMISSAL WITHOUT PREJUDICE AS TO THIRD- PARTY DEFENDANT JILL GHANBARIAN, FNP; ORDER
The parties hereby stipulate, by and through their respective counsel, that Third-Party Defendant Jill Ghanbarian, FNP, is an employee of Third-Party Defendant Children's Hospital Central California and at all relevant times was acting within the scope of her employment. At all relevant times, counsel for Children's Hospital Central California has represented Jill Ghanbarian FNP in her capacity as an employee. Children's Hospital Central California stipulates that it is responsible for all of the acts and omissions of Jill Ghanbarian FNP in connection with this case and will agree to indemnify the Third-Party Plaintiff United States for any and all liability, if any, assessed against Jill Ghanbarain, FNP in this matter.
Based on the above, the parties hereby stipulate that
Third-Party Defendant Jill Ghanbarian, FNP be dismissed without prejudice from this action and that Jill Ghanbarian FNP, will bear her own costs and fees, if any, arising from this action. The parties request the Court endorse this stipulation by way of formal order.
Dated: December 1, 2009.
GWILLIAM, IVARY, CHIOSSO, CAVALLI & BREWER (As authorized 12/01/09)
By: Steven J. Brewer Attorneys for Plaintiff
Dated: November 30, 2009.
MCNAMARA, DODGE, NEY, BEATTY, SLATTERY, PFALZER, BORGES & BROTHERS, LLP (As authorized 11/30/09)
By: Robert W. Hodges Attorneys for Third-Party Defendant, David Hodge, MD
Dated: December 4, 2009.
STAMMER, MCKNIGHT, BARNUM & BAILEY, LLP (As authorized 12/04/09)
By: Jerry D. Jones Attorneys for Third-Party Defendants, Children's Hospital Central California and Jill Ghanbarian, FNP
Dated: December 2, 2009.
MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH, LLP (As authorized 12/02/09)
By: Lawrence E. Wayte Attorneys for Third-Party Defendant, John E. Dinsmore, MD
Dated: December 3, 2009.
BENJAMIN B. WAGNER United States Attorney
Pursuant to Federal Rule of Civil Procedure 41(a)(2) and the terms of the stipulation set forth above, Third-Party Defendant Jill Ghanbarian, FNP is hereby dismissed without prejudice.
IT IS SO ORDERED.
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