Ropers Majeski Kohn & Bentley 

A Professional Corporation 

Redwood City 

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RC1/420236.1/LD - 1 - STIPULATION AND ORDER OF DISMISSAL 

 CIV. S-04-0047 GEB PAN 

ROBERT P. ANDRIS (SBN 130290) 

ELISE R. VASQUEZ (SBN 201190) 

ROPERS, MAJESKI, KOHN & BENTLEY 

1001 Marshall Street, Suite 300 

Redwood City, CA 94063 

Telephone: (650) 364-8200 

Facsimile: (650) 780-1701 

Email: randris@ropers.com 

 evasquez@ropers.com 

Attorneys for Defendant 

UNITED TREASURES, INC. 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

KEITH STAFFORD, an individual, 

Plaintiff, 

v. 

UNITED TREASURES, INC., a 

Washington corporation, 

Defendant. 

CASE NO. CIV. S-04-0047 GEB PAN 

STIPULATION AND ORDER OF 

DISMISSAL 

AND RELATED ACTION. 

I. 

STIPULATION

Plaintiff Keith Stafford (“Stafford”), by and through his attorney of record, Stephen L. 

Davis of Davis & Leonard LLP, and defendant United Treasures, Inc. (“United Treasures”), by 

and through its attorney of record, Robert P. Andris of Ropers, Majeski, Kohn & Bentley, have 

entered into a complete and final settlement resolving all claims, counterclaims, causes of action, 

and other demands asserted in the above-captioned proceeding. In accordance with and pursuant 

to such settlement, Stafford and United Treasures (collectively, the “Parties”) hereby stipulate and 

agree as follows: 

/// 

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RC1/420236.1/LD - 2 - STIPULATION AND ORDER OF DISMISSAL 

 CIV. S-04-0047 GEB PAN 

1. All claims, counterclaims, causes of action, and other demands asserted by the 

Parties in this proceeding have been fully and finally settled and released. 

2. The Parties have agreed that the above-captioned proceeding should be dismissed 

in its entirety, with prejudice and without an award of costs or attorney fees to either of the 

Parties. 

3. The Parties have agreed that the Court's May 17, 2005 Order entered on the 

Parties’ summary-judgment motions in this proceeding should be vacated and superseded by this 

Stipulation and Order of Dismissal. 

DATED this 20th day of November 2006. 

DAVIS & LEONARD LLP 

By: /s/ Stephen L. Davis 

Stephen L. Davis 

Attorneys for Plaintiff Keith Stafford 

ROPERS, MAJESKI, KOHN & BENTLEY 

By: /s/ Robert P. Andris 

Robert P. Andris 

Attorneys for Defendant United Treasures, Inc. 

II. 

ORDER

This matter came before the Court on the date set forth below upon the stipulation set 

forth above. Having considered the premises, 

THE COURT HEREBY ORDERS, ADJUDGES, AND DECREES as follows: 

A. The stipulation set forth above is approved and incorporated herein by this 

reference. 

B. The May 17, 2005, Order entered on the Parties' summary-judgment motions in 

this proceeding (the "Order on SJ Motions") is vacated and superseded by this Stipulation and 

Order of Dismissal. The Order on SJ Motions is null and void in its entirety, and it shall have no 

force or effect whatsoever. 

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RC1/420236.1/LD - 3 - STIPULATION AND ORDER OF DISMISSAL 

 CIV. S-04-0047 GEB PAN 

C. The above-captioned proceeding is dismissed in its entirety, with prejudice and 

without an award of costs or attorney fees to either of the Parties. The dismissal includes all 

claims, counterclaims causes of action, and other demands asserted by the Parties in this 

proceeding. 

DATED: December 8, 2006 

Case 2:04-cv-00047-GEB-EFB Document 159 Filed 12/11/06 Page 3 of 3