Lopez, et al. v. County of Tulare, et al.

Filing 27

JOINT STIPULATION OF THE PARTIES; ORDER signed by District Judge Lawrence J. O'Neill on December 7, 2011. (Munoz, I)

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DENNIS R. THELEN, SBN 83999
KEVIN E. THELEN, SBN 252665

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LAW OFFICES OF

LE BEAU • THELEN , LLP
5001 East Commercenter Drive, Suite 300
Post Office Box 12092
Bakersfield, California 93389-2092
[phone]; Fax [phone]

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KATHLEEN BALES-LANGE, #094765
County Counsel for the County of Tulare
TERESA M. SAUCEDO, #093121
Chief Deputy County Counsel
2900 West Burrell, County Civic Center
Visalia, CA 93291
Phone: [phone]; Fax [phone]

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Attorneys for Defendants, COUNTY OF TULARE, TULARE
COUNTY SHERIFF'S DEPARTMENT, TULARE COUNTY
SHERIFF-CORONER WILLIAM WITMANN, AND
DEPUTY CHRISTOPHER LANDIN

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MARIO LOPEZ JR., DECEASED,
THROUGH HIS CO-SUCCESSORS IN
INTEREST, MARIO LOPEZ III AND
MICHAEL LOPEZ; ELIDA LOPEZ,
Individually; MARIO LOPEZ III, Individually;
and MICHAEL LOPEZ, Individually,

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Plaintiffs,

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COUNTY OF TULARE, a public entity,
TULARE COUNTY SHERIFF'S
DEPARTMENT, a public entity, TULARE
COUNTY SHERIFF-CORONER WILLIAM
WITTMAN, in his individual and official
capacities, DEPUTY CHRISTOPHER
LANDIN, Individually, and DOES 1 through
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JOINT STIPULATION OF THE
PARTIES; ORDER

vs.

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CASE NO.: 1:11-cv-01547-LJO-SMS

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Case Filed:
Trial Date:

September 14, 2011
None set

Defendants.

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JOINT STIPULATION OF THE PARTIES; [PROPOSED] ORDER

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The parties to the above referenced action, subject to the Court's approval, hereby stipulate to
the following:

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WHEREAS the parties desire to provide counsel for defendants further time to prepare a reply

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to plaintiffs' Opposition to defendants' Motion to Dismiss and Motion to Strike pursuant to the Federal

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Rules of Civil Procedure;

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WHEREAS counsel for plaintiffs provided a similar professional courtesy to counsel for
defendants in allowing defendants further time to respond to the Plaintiffs' Complaint;

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WHEREAS counsel for defendants provided a similar professional courtesy to counsel for

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plaintiffs in allowing plaintiffs further time to respond to the Defendants' Motion to Dismiss and Motion

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to Strike;

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WHEREAS counsel for defendant has multiple pressing matters, including three days of out-of-

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town events, that will prevent counsel from preparing a full and complete reply to Plaintiffs' Opposition

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to defendants' Motion to Dismiss and Motion to Strike on the currently set briefing schedule;

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The parties HEREBY AGREE, subject to the Court's approval, to modify the time frames
relating to the defendants' Motion to Dismiss and Motion to Strike as follows:

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1.

Defendants' Reply to Plaintiffs' Opposition to Defendants' Motion to Dismiss and Motion

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to Strike was previously scheduled to be filed on or before Wednesday, December 7, 2011;

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JOINT STIPULATION OF THE PARTIES; [PROPOSED] ORDER

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2.

Defendants' Reply to Plaintiffs' Opposition to Defendants' Motion to Dismiss and Motion

to Strike shall now be set to be filed on or before Tuesday, December 13, 2011;

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Respectfully submitted,
Dated: December 7, 2011

LeBEAU • THELEN, LLP

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By:

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/S/ DENNIS R. THELEN
DENNIS R. THELEN, ESQ.
Attorneys for Defendants
COUNTY OF TULARE

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Dated: December 7, 2011

KATHLEEN BALES-LANGE
Tulare County Counsel

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By:
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/S/ TERESA M. SAUCEDO
TERESA M. SAUCEDO
Attorneys for Defendants
COUNTY OF TULARE, TULARE COUNTY
SHERIFF'S DEPARTMENT, TULARE
COUNTY SHERIFF-CORONER WILLIAM
WITTMAN, AND DEPUTY CHRISTOPHER
LANDIN

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Dated: December 7, 2011

HADDAD & SHERWIN

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By:

/S/ MICHAEL HADDAD
MICHAEL HADDAD, ESQ.
Attorneys for Plaintiffs MARIO LOPEZ JR.,
D E C E A S E D , T H R O U G H H IS C O SUCCESSORS IN INTEREST, MARIO LOPEZ
III AND MICHAEL LOPEZ; ELIDA LOPEZ,
Individually; MARIO LOPEZ III, Individually;
and MICHAEL LOPEZ, Individually,

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JOINT STIPULATION OF THE PARTIES; [PROPOSED] ORDER

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ORDER

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This Court APPROVES the proposed revised deadline to file reply papers and LIMITS reply
points and authorities to no more than 10 pages.

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IT IS SO ORDERED.
Dated:
66h44d

December 7, 2011

/s/ Lawrence J. O'Neill
UNITED STATES DISTRICT JUDGE

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JOINT STIPULATION OF THE PARTIES; [PROPOSED] ORDER