Page 1 – STIPULATED JUDGMENT OF DISMISSAL PURSUANT 

TO FRCP 41(a)(ii) 

SLINDE NELSON STANFORD

111 SW 5th Ave, Suite 1940

Portland, Oregon 97204

p. 503.417.7777; f. 503.417.4250

R. Hunter Bitner, II, OSB No. 011146 

hunter@slindenelson.com

SLINDE NELSON STANFORD 

111 SW Fifth Avenue, Suite 1940 

Portland, OR 97204 

Tel: 503-417-7777 

Fax: 503-417-4250 

 Of Attorneys for Plaintiff 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

MEDFORD DIVISION 

THE UNITED STATES OF AMERICA FOR 

THE USE AND BENEFIT OF ASHLAND 

MEDFORD PLUMBING, INC., an Oregon 

corporation; and ASHLAND MEDFORD 

PLUMBING, INC., an Oregon Corporation, 

 

Plaintiffs, 

v. 

KEVCON, INC., a California corporation; 

and SAFECO INSURANCE COMPANY OF 

AMERICA, a Massachusetts corporation, 

 

Defendants. 

Case No. 1:15-cv-00132-MC 

STIPULATED JUDGMENT OF 

DISMISSAL PURSUANT TO FRCP 

41(a)(ii) 

 Pursuant to FRCP 41(a)(ii), the parties, through their attorneys of record, having fully 

compromised and settled this matter, hereby stipulate that all claims herein may be dismissed, with 

prejudice, and without fees or costs to any party. 

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Case 1:15-cv-00132-MC Document 43 Filed 04/20/16 Page 1 of 3
Page 2 – STIPULATED JUDGMENT OF DISMISSAL PURSUANT 

TO FRCP 41(a)(ii) 

SLINDE NELSON STANFORD

111 SW 5th Ave, Suite 1940

Portland, Oregon 97204

p. 503.417.7777; f. 503.417.4250

THEREFORE, pursuant to the stipulation of the parties below, it is hereby: 

ORDERED AND ADJUDGED that all claims herein against Kevcon, Inc. and Safeco 

Insurance Company of America, are dismissed, with prejudice, and without fees or costs to any 

party and all counterclaims against Ashland Medford Plumbing, Inc. 

Dated this __ of April, 2016. 

The Honorable Michael J. McShane 

United States District Court Judge 

IT IS SO STIPULATED: 

Respectfully submitted April 19, 2016. 

WILLIAMS KASTNER & GIBBS PLLC 

By: /s/ Thomas A. Ped 

Thomas A. Ped, OSB No. 842203 

 Attorneys for Defendants 

SLINDE NELSON STANFORD 

By: /s/ R. Hunter Bitner, II 

R. Hunter, Bitner, II, OSB No. 011146 

 Attorneys for Plaintiff 

20

Case 1:15-cv-00132-MC Document 43 Filed 04/20/16 Page 2 of 3
Page 1 – CERTIFICATE OF SERVICE SLINDE NELSON STANFORD

111 SW 5th Ave, Suite 1940

Portland, Oregon 97204

p. 503.417.7777; f. 503.417.4250

CERTIFICATE OF SERVICE 

 I hereby certify that I served the foregoing STIPULATED JUDGMENT OF DISMISSAL 

PURSUANT TO FRCP 41(a)(ii) on: 

Thomas A. Ped, OSB No. 953767 

tped@williamskastne.com

WILLIAMS, KASTNER & GIBBS PLLC 

888 SW Fifth Avenue, Suite 600 

Portland OR 97204 

Phone: (503) 228-7967 

Of Attorneys for Defendants 

 

by the following indicated method(s): 

 by faxing full, true, and correct copies thereof to said attorney to the fax number noted 

above, which is the last known fax number for said attorney, on the date set forth below. 

 by emailing full, true, and correct copies thereof to said attorney to the email address noted 

above, which is the last known email address for said attorney, on the date set forth below. 

 by notice of electronic filing using the CM/ECF system. 

 by causing full, true and correct copies thereof to be mailed to the party(s) at the party’(s) 

last-known office address(es) listed above on the date set forth below. 

DATED: April 19, 2016. 

SLINDE NELSON STANFORD 

By: R. Hunter Bitner, II 

 R. Hunter Bitner, II, OSB No. 011146 

 Of Attorneys for Plaintiff

Case 1:15-cv-00132-MC Document 43 Filed 04/20/16 Page 3 of 3