Torres, et al v. City of Madera, et al

Filing 246

STIPULATION and ORDER to Continue Pretrial Conference signed by District Judge Anthony W. Ishii on 06/18/2013. Pretrial Conference set for 8/6/2013 at 08:30 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii. (Flores, E)

Case 1:02-cv-06385-AWI-GSA Document 245 Filed 06/13/13 Page 1 of 3
'-l; Law Offices of

.loung~)

Nichols

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FILED

A Partnership Composed uf Prufeuiunlll Curptit'alinn!t

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1901 Truxrun Avenue
p.o. Box 2347 • Haker~field, CA 93303

Telephone 661·861-7911 • facsimile 661·861·7932

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THOMAS A. BRILL, ESQ., SBN 125356

Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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II

******

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MARIA TORRES and MELCHOR
TORRES, individually and as
Administrators of the Estate of
EVERARDO TORRES,

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Plaintiffs,

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CASE NO.: CIV-F-02-6385AWI (UO)

STIPULATION TO CONTINUE
PRETRIAL CONFERENCE

CURRENT DATE: AUGUST 1,2013

vs.
CITY OF MADERA, MARY NORIEGA,

indivdually and as a member of the

Madera Police Department; and DOES 1

through 50,

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Defendants.

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IT IS HEREBY STIPULATED, by and between the parties herein, through their respective

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counsel of record, that the Pretrial Conference scheduled for August 1, 2013 be continued for a

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short time for the following reasons:
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1.

Counsel for Plaintiff, Thomas A. Brill, of the law offices of Young & Nichols, is

taking the Hawaii State Bar Examination on July 30 and July 31. 2013. He will be unable to
attend the Pretrial Conference currently scheduled for August 1,2013 at 8:30 a.m. in Courtroom

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2 of this Court.

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STIPULATION TO CONTINUE PRETRIAL CONFERENCE

Case 1:02-cv-06385-AWI-GSA Document 245 Filed 06113113
2.

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Thomas A. Brill is the trial attorney for Plaintiffs who will be trying this case, and

is the only attorney at Young & Nichols with any familiarity with the case.
3.

Mr. Brill originally scheduled to take the Hawaii State Bar in February, 2013, but

due to an issue with documentation, he was unable to take the exam in February. The bar

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examiners did, however, hold the application open for the July Bar exam and allowed Mr. Brill
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to take the examination in July once the issue had been resolved.
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Mr. Brill has expended substantial time and money in preparing for the bar

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examination, including enrolling in a BARBRI course at a cost of over $2,000, and has

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expended at least 60 hours a week studying since late May, 2013. In addition, Mr. Brill has

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tickets to travel to Hawaii to be able to take the examination.

5.

Plaintiffs counsel is well aware of the scheduling issues this Court has as a result

of being short-staffed, but under the circumstances is requesting a one week continuance of the
Pretrial Conference so that Mr. Brill can attend the hearing without being required to cancel his
plans to take the bar examination.

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The continuance will not affect the trial date in this matter,
Defense counsel, Bruce D. Praet, of Ferguson, Praet & Sherman has stipulated to

the change of hearing date, and agrees to the requested date of August 8, 2013, at a time

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convenient to the court's calendar.
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Plaintiffs therefore request that this Court continue the Pretrial Conference date

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from August 1,2013, to August 8,2013, or such other time after August 5,2013 that is

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convenient to the court's calendar.

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DATED: June 12,2013

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By~~~______~~=--=

_______

, ,ESQ.
Attorneys for Plaintiffs
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STIPULATION TO CONTINUE PRETRlAL CONFERENCE

Case 1:02-cv-06385-AWI-GSA Document 245 Filed 06/13/13 Page 3 of 3

IT IS SO STlPULATED.

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DATED: June/-Z; 2013

FERGUSON, PRAET & SHERMAN

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BRUCE D. PRAET. ESQ.
Attorneys for Defendants

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IT IS SO ORDERED.

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The Pretrial Conference will be rescheduled to

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Courtroom 2 of this Court.

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,at 8:30 a.m. in

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STlPLI.ATlON TO CONTINUE PRETRIAL CONFERENCE