Ernest DeWayne Jones v. Robert K. Wong

Filing 13

STIPULATION to Continue Initial Case Management Conference from June 12, 2009 to TBD filed by Petitioner Ernest DeWayne Jones. (Attachments: # 1 Proposed Order)(Laurence, Michael)

1

)

MICHAEL LAURENCE (State Bar No. 121854)
PATRICIA C. DANIELS TState Bar No. 162S6g)
HABEAS CORPUS RESOURCE CENTER

5

303 Second Street, Suite 400 South
San Francisco. California 94107
Telenhon e: Gl5) 348-3800
Facsimile : (qtsj l+g-lgll
Mlauren c e@hci c .ca. gov
do cketing@Ycrc. ca. gov

6

Attorneys for Petitioner Ernest Dewayne Jones

7

EDMUND G. BROWN JR.
Attorney General of the State of California
DANE R. GILLETTE
Chief Assistant Attorney General
PAMAELA C. HAMANAKA
Senior Assistant Attornev General
HERBERT S. TETEF (State BarNo. 185303)
Deoutv Attornev Geneial
300 S5uth Soriris Street. Suite 1702
Los Anseles^. CA 90012'
Teleoho"n e: 01 3) 897-0201

3
4

8
9
10
11

12
13

Facsimile : (213\' 897 -6496
Herbert. Tetdf@doj ca. gov

t4

Attorneys for Respondent ROBERT K. WONG

.

15

t6

UNITED STATES DISTRICT COURT

t7

FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION

18

t9

ERNEST DEWAYNE JONES,

2l
22
23

DEATH PENALTY CASE

Petitioner,

20

Case Number CV -09-2158-CJC

V.

ROBERT K. WONG. Actine Warden
of California State' Prisori at San

STIPULATION AND REQUEST FOR
ORDER CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE

Quentin,

24

Respondent.

25
26

The parties in this action stipulate to and seek an order continuing the Initial

27

Case Management Conference, currently set for June 12,2009 at 10:30 a.m., to a date

28

stipulated

to by both

counsel and which

STIPULATION AND ORDER CHANGING

TIME OF JOINT CASE MANAGEMENT CONFERENCE
JONES V. WONG,NO. CV-09-2158-CJC

is most convenient to the Court.

1

As set forth in the attached Declaration of Michael Laurence in Support of

2

Stipulation and Request for Order Continuing Initial Case Management Conference,

3

good cause exists

4

petitioner's counsel, Michael Laurence, will be out of the state and thus unavailable to

5

appear on June 12,2009.

6
7

to continue the Initial

Case Management Conference because

Counsel for respondent and counsel for petitioner stipulate they are available for
a rescheduled

Initial Case Management Conference on the following dates:

8

June 5,2009;

9

July 1 4, 16, 17 , 20 , and 2l , 2009 .

10
11

A Proposed Order Continuing Initial Case Management Conference is submitted
herewith.

t2
13

Dated: May

f,

2009

HABEAS CORPUS RESOURCE CENTER

t4

l5
t6

Bv: MICHAEL LATIRENCE

Auorneys for Petitioner Ernest DeWayne Jones

t7
18

t9

iDated:

MuyS

ZOO}

ATTORNEY GENERAL OF TFTE STATE OF
CALIFORNIA

20

2l
22
23

By: FIERBERT S. TETEF
D-eoutv Affomev General
Atdomeys for Ri:spondent Robert K. Wong

24
25
26
27
28
STIPULATION AND ORDER CHANGING
TIME OF JOINT CASE MANAGEMENT CONFERENCE
JONES V. \|/ONG,NO. CV-09-21 58-CJC

I

DECLARATION OF MICHAEL LATJRENCE IN SUPPORT OF STIPULATION AND

,,

REQUEST FOR ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE

3

I, Michael Laurence, declare as follows:

4

1.

I

am the attomey appointed as lead counsel for Petitioner Ernest DeWayne Jones in

I

5

the above-referenced matter by this Court in an order dated April 14, 2009.

6

Director of the Habeas Corpus Resource Center, a Califomia judicial branch entity that the California

7

Supreme Court appointed to represent Mr. Jones in his state habeas corpus and executive clemency

8

proceedings.

2.

9

10

By order dated Apnl 23, 2009, this Court scheduled the lnitial Case Management

Conference in this matter for June 12,2009, at 10:30 a.m.

3.

11
12

am the Executive

Prior to this Court's order,

I

agreed to instruct at a national training seminar at New

York University School of Law in New York on June l2-I4,2009.

4.

13

Counsel for Mr. Jones conferred about this conflict with counsel for respondent, who

l4

agreed

15

management may be continued.

to stipulate to a continuance of this mattet, and agreed upon several dates to which the case

5.
6.

l6
l7

There have been no prior requests for continuances in this matter by either party.

I therefore respectfully

request that the matter be continued from June 12, 2009, at

18

10:30 a.m. to one of the dates stipulated to by both counsel and which is most convenient to the

t9

Court.

The foregoing is true and correct and executed under penalty of perjury under the laws of the

20

2l

United States on May $ ,2009.

22
23

24

MICHAEL LAURENCE

25
26
27
28

2
DECLARATToN oF MICHAEL LAURENcE

nt SuPpoRr

or

Srrpur-nrroN nxo Rrquesr ron ORoBn CoNTTNUINc

INnnr

CASE MENECSIVIENT CONFERENCE

Casn No. 09-CV-2158-crc