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)

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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

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