609.919.6609

rrosenbIattmorgan1ewLscom

RECEIVED

August 29,2012 AUG 2 9 2012

VIA FACSIMILE [856357.5355] AND US. MAIL

U.s. MaiStrt Judo,

The Honorable Joel Schneider

United States Magistrate Judge

United States District Court, District ofNew JerseyMitchell H. Cohen Building & U.S. Courthouse

1 John F. Gerry Plaza, Room 2060

Camden, New Jersey 08101-0887

Re: Shelly Martin, et al. v. AtlantiCare, et al.

Case No. 1:1O-cv-06793 - Dear Judge Schneider:

We represent Defendants in the above-referenced matter. We write at the request of your

judicial assistant to inform you that the parties in this matter have reached an amicable resolution

oftheir dispute, and have executed the attached Stipulation ofDismissal With Prejudice

(“Stipulation”).

As you know, in addition to the Complaint filed in this action, the Plaintiffs individually filedVerified Complaints with the New Jersey Division on Civil Rights (“DCR”) in June 2012. TheDCR has facilitated settlement negotiations between the parties. On August 27,2012, we spoke

with Plaintiffs’ counsel ofrecord, Brian Dratch, and received his permission to negotiate the

terms of a settlement through the assistance ofthe representatives at the DCR’s Atlantic City

office.

On August 28, the parties executed settlement agreements which included an agreement by

Plaintiffs to execute the attached Stipulation with respect to this action, in addition to

withdrawing their complaints pending before the DCR.

Philadelphia Washington New York Los Angeles San Francisco Miami Pittsburgh Princeton Chicego Palo Alto

Dallas Houston Harrisburg Irvine Boston Wilmington London Paris Brussels Frankfurt Beijing Tokyo
We therefore respectfully request that the Court grant permission to file the attached Stipulation,

and enter an Order ofDismissal with Prejudice as to all parties and all issues in this matter.

Respectfully submitted,

/J?L/

Richard 0. Rosenblatt

RGRJNS/kmb

w/enclosure

cc: Brian M. Dratch, Esquire (via e-mail)
SIIELLY MARTIN, KARLA MAYFIELD

And DONNA M. DAVIS,

Civil Action No. 1:1O-cv-06793-JI{R -

Plaintiffs, AMD

vs.

STIPULATION OF DISMISSAL

WITH PREJUDICE

ATLANTICARE, ATLANTICARE

BEHAVIORAL HEALTH, : ELECTRONICALLYFILE!)

ATLANTICARE REGIONAL MEDICAL

CENTER, ATLANTICARECORPORATE, ATLANTICARE

HEALTH ENGAGEMENT,

ATLANTICARE HEALTH SERVICES,

ATLANTICARE SURGERY CENTER,

ATLANTICARE

INFOSHARE!ATLANTICARE

INFORMATION TECHNOLOGY,

CAROLINE BAlER, Individually,

ROSE TJHLAND, Individually, and

John Does 1-5 and 640,

Defendants.

STIPULATION OF DISMISSAL WITH PREJUDICE

Pursuant to Rule 41(aXl) ofthe Federal Rules ofCivil Procedure, the parties to this

action, Plaintiffs Shelley Martin, Karla Mayfleld and Donna M. Davis, and Defendants

AtlantiCare Regional Medical Center, Carolyn Baler and Rose Uhiand, stipulate to the dismissal

- 12-
‘fI’l4W7’Glenn Avenue

Egg Harbor Township, NJ 08234

Plaintiff appearin 0 Se.

la a el

5 nroe nue

antic City, NJ 08401

Plaintiff appearingpro se

uiiiOt.Lfrfl

Donna M. Davis

135 New Jersey Ave.

Atlantic City, NJ 08401

Plaintiff appearingpro se

Richard G. o nblatt, Esq.

Morgan, Lewis & Bockius LLP

502 Carnegie Center

Princeton, NJ 08540

Telephone: 609.919.6609

rrosenblattmorgnIewis.com

Attorneysfor Defendants AtlantiCare Regional

Medical Center, Carolyn Baler andRose Uhiand.

13

TTAL F .