Rangel v. American Medical Response West et al

Filing 111

STIPULATION and ORDER setting Pre-trial Conference set for 11/21/2014 at 08:30 AM and Jury Trial set for 1/21/2015 at 08:30 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii, signed by District Judge Anthony W. Ishii on 4/22/2014. (Kusamura, W)

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WILLIAM J. SMITH, Bar No. 056116
SMITH JOHNSON, INC.
5588 N. Palm Avenue
Fresno, CA 93704
Telephone: [phone]

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Attorneys for Plaintiff, DEANNA RANGEL

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DANIEL F. FEARS, Bar No. 110573
LEILA NARVID, Bar No. 229402
E-Mail: [e-mail]
E-Mail: [e-mail]
PAYNE & FEARS LLP
One Post Street, Suite 1000
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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ATTORNEYS AT LAW

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ONE POST STREET, SUITE 1000
SAN FRANCISCO, CALIFORNIA 94104
[phone]

PAYNE & FEARS LLP

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Attorneys for Defendants
AMERICAN MEDICAL RESPONSE WEST
and TRACY J. FISCHER
JEFFREY P. DAVIS, Bar No. 166484
MARK D. KRUTHERS, Bar No. 179750
MICAH K. NILSSON, Bar No. 250919
DOWLING, AARON & KEELER, INC.
8080 North Palm Avenue, Third Floor
P. O. Box 28902
Fresno, CA 93729-8902
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant, JOSE MARTINEZ

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UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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DEANNA RANGEL,

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FRESNO DIVISION
CASE NO. 1:09-CV-01467-AWI-GSA

Plaintiff,
v.
AMERICAN MEDICAL RESPONSE
WEST, a California corporation, JOSE
MARTINEZ, an individual (as to GC §
12940 and Defamation only), and TRACY J.

STIPULATION AND ORDER SETTING
PRE-TRIAL CONFERENCE AND TRIAL
DATES
Courtroom:
Judge:

STIPULATION AND [PROPOSED] ORDER SETTING PRE-TRIAL
CONFERENCE AND TRIAL DATES

2, 8th Floor
Hon. Anthony W. Ishii

Case No. 1:09-CV-01467-AWI-GSA

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FISHER, an individual (Defamation only),
Complaint filed:

Defendants.

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August 20, 2009

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STIPULATION AND REQUEST
Plaintiff Deanna Rangel (“Plaintiff”), on the one hand, and Defendants American Medical

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Response West (“AMR”) and Tracy J. Fischer (“Fischer”) (collectively “the AMR parties”) and

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Jose Martinez (“Martinez”) on the other hand (collectively, “the Parties”), through their respective

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attorneys of record, jointly stipulate and request that the Court set new Pre-Trial Conference and

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Trial dates on the following grounds:

ATTORNEYS AT LAW

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ONE POST STREET, SUITE 1000
SAN FRANCISCO, CALIFORNIA 94104
[phone]

PAYNE & FEARS LLP

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WHEREAS on March 4, 2014, the Court issued an order vacating the Pre-Trial Conference
set for March 12, 2014 and the Jury Trial set for May 6, 2014;

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WHEREAS the Parties have agreed upon a mediator and are in the process of scheduling a
mediation for mid-June 2014;

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WHEREAS the Parties jointly stipulate and request that the Court set a Pre-Trial

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Conference on November 21, 2014 and a Jury Trial on January 20, 2015;

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THEREFORE, the Parties hereby STIPULATE as follows:

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1.

The Pre-Trial conference shall be set for November 21, 2014, and the Jury Trial

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shall be set for January 20, 2015, and respectfully request that the Court enter an order on this

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Stipulation.

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DATED: April 22, 2014

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SMITH JOHNSON, INC.

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By: /s/ William J. Smith
WILLIAM J. SMITH

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Attorneys for Plaintiff
DEANNA RANGEL

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STIPULATION AND [PROPOSED] ORDER SETTING PRE-TRIAL
CONFERENCE AND TRIAL DATES

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Case No. 1:09-CV-01467-AWI-GSA

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DATED: April 22, 2014

PAYNE & FEARS LLP

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By: /s/ Leila Narvid
DANIEL F. FEARS
LEILA NARVID

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Attorneys for Defendants
AMERICAN MEDICAL RESPONSE WEST and
TRACY J. FISCHER

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DATED: April 22, 2014

DOWLING, AARON & KEELER, INC.

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By: /s/ Mark D. Kruthers
MARK D. KRUTHERS

ATTORNEYS AT LAW

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ONE POST STREET, SUITE 1000
SAN FRANCISCO, CALIFORNIA 94104
[phone]

PAYNE & FEARS LLP

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Attorneys for Defendant
JOSE MARTINEZ

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ORDER

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Upon reading the Parties’ Stipulation and good cause appearing, the Pre-Trial Conference

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is set for November 21, 2014 at _8:30 a.m. in this Department. The Parties shall file Pre-Trial
Conference Statements by November 10, 2014. The Jury Trial is set for Wednesday, January
21, 2015 at 8:30 a.m. in this Department.
IT IS SO ORDERED.
Dated: April 22, 2014
SENIOR DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER SETTING PRE-TRIAL
CONFERENCE AND TRIAL DATES

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Case No. 1:09-CV-01467-AWI-GSA