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STIPULATION AND ORDER DISMISSING 

ENTIRE ACTION, WITH PREJUDICE, C17-228 

JCS 

NOAH G. BLECHMAN (State Bar No. 197167)

noah.blechman@mcnamaralaw.com 

AMY S. ROTHMAN (State Bar No. 308133) 

amy.rothman@mcnamaralaw.com 

MCNAMARA, NEY, BEATTY, SLATTERY,

BORGES & AMBACHER LLP 

3480 Buskirk Avenue, Suite 250 

Pleasant Hill, CA 94523 

Telephone: (925) 939-5330 

Facsimile: (925) 939-0203 

Attorneys for Defendants 

CITY OF PITTSBURG, and OFFICER MICHAEL KEEFE 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

WORSTEN ANDREWS,

Plaintiff, 

vs. 

CITY OF PITTSBURG, a municipal 

corporation; OFFICER MICHAEL KEEFE, 

individually and in his Official Capacity as 

a Police Officer for the CITY OF 

PITTSBURG; DOES 1-50, inclusive; 

individually and in their official capacities 

and POLICE OFFICERS for the CITY OF 

PITTSBURG, 

Defendant. 

Case No. C17-228 JCS

STIPULATION AND [PROPOSED] 

ORDER DISMISSING ENTIRE ACTION, 

WITH PREJUDICE 

Judge: Hon. Joseph C. Spero 

The relevant parties, by and through their respective attorneys of record, hereby stipulate 

and jointly request an Order from the Court to a dismissal of the Plaintiff’s Complaint, the entire 

action, against Defendants CITY OF PITTSBURG and OFFICER MICHAEL KEEFE, and any 

and all employees and/or agents of the City of Pittsburg, with prejudice. Each party agrees to 

bear its own fees and costs as to this dismissal 

/ / / 

/ / / 

Case 3:17-cv-00228-JCS Document 76 Filed 08/27/19 Page 1 of 2
McN

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1

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STIPULATION AND ORDER DISMISSING 

ENTIRE ACTION, WITH PREJUDICE, C17-228 

JCS 

2

The parties attest that concurrence in the filing of these documents has been obtained from 

each of the other Signatories, which shall serve in lieu of their signatures on the document. 

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 

Dated: August 26, 2019 Law Offices of Brittany Hendrix-Smith 

By: /s/ Smith, Brittany H. 

 Brittany H. Smith 

 Attorney for Plaintiff, 

 WORSTEN ANDREWS 

Dated: August 26, 2019 MCNAMARA, NEY, BEATTY, SLATTERY,

BORGES & AMBACHER LLP

By: /s/ Rothman, Amy 

Noah G. Blechman 

Amy S. Rothman 

Attorneys for Defendants 

City of Pittsburg and Officer Michael Keefe 

ORDER 

PURSUANT TO STIPULATION AND REQUEST, IT IS ORDERED AS FOLLOWS: 

The Court hereby dismisses this entire action, with prejudice, as to all claims alleged by 

Plaintiff. Each party to bear its own fees and costs as to this dismissal. 

IT IS SO ORDERED 

Dated: _____________, 2019 By: 

Hon. Joseph C. Spero 

U.S. Chief Magistrate Judge 

Case 3:17-cv-00228-JCS Document 76 Filed 08/27/19 Page 2 of 2