Youngblood v. City of Bakersfield et al

Filing 67

STIPULATION and ORDER to continue the Pretrial Conference to 12/11/2014 at 11:00 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii and the Jury Trial to 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 6/18/2014. (Kusamura, W)

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DANIEL RODRIGUEZ, ESQ., SBN 096625
JOEL T. ANDREESEN, ESQ., SBN 152254
MARTHA J. ROSSITER, ESQ., SBN 256234
RODRIGUEZ & ASSOCIATES
2020 EYE STREET, BAKERSFIELD, CA 93301
TELEPHONE: [phone] FAX: [phone]
Attorneys for Plaintiff VICTORIA YOUNGBLOOD

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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VICTORIA P. YOUNGBLOOD,

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Plaintiff,

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vs.

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CITY OF BAKERSFIELD,
CHRISTOPHER DALTON, GREG
WILLIAMSON, and DOES 1 to 100,
Inclusive,
Defendants.

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Case No. 1:12-CV-01150-AWI-JLT
STIPULATION AND ORDER TO
CONTINUE TRIAL DATE TO
JANUARY 21, 2015

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Victoria Youngblood, through the undersigned counsel of record, and defendants

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City of Bakersfield, Christopher Dalton, and Greg Williamson, through their undersigned

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counsel of record, hereby stipulate and respectfully request the Court to continue the trial

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date to January 21, 2015.

STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER - 1

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The matter was originally set for trial on April 22, 2014. On its own motion, the

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Court continued the case to May 20, 2014. However, defense counsel had a conflict on

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that date and as such, the Court advised the parties to meet and confer to select a new

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date that worked for all parties. The parties stipulated to vacate the May 20, 2014 trial

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date, which the Court ordered. [See Dkt No. 62].

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Having met and conferred, the parties respectfully request that the Court reset the

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trial of this matter to January 21, 2015 and set the pretrial conference on or about

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December 11, 2014.

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IT IS SO STIPULATED.

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Respectfully submitted,

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Dated: June 18, 2014

RODRIGUEZ & ASSOCIATES

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____________________________
Martha J. Rossiter
Attorney for Plaintiff

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Dated: June 18, 2014

CITY OF BAKERSFIELD

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____________________________
Michael Marderosian
Attorney for Defendants

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STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER - 2

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DANIEL RODRIGUEZ, ESQ., SBN 096625
JOEL T. ANDREESEN, ESQ., SBN 152254
MARTHA J. ROSSITER, ESQ., SBN 256234
RODRIGUEZ & ASSOCIATES
2020 EYE STREET, BAKERSFIELD, CA 93301
TELEPHONE: [phone] FAX: [phone]
Attorneys for Plaintiff VICTORIA YOUNGBLOOD

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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VICTORIA P. YOUNGBLOOD,

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Plaintiff,

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vs.

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CITY OF BAKERSFIELD,
CHRISTOPHER DALTON, GREG
WILLIAMSON, and DOES 1 to 100,
Inclusive,
Defendants.

) Case No. 1:12-CV-01150-AWI-JLT
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) ORDER CONTINUING TRIAL DATE
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This matter came before the Court on the parties’ stipulation to continue the trial
date to January 21, 2015. The Court ADOPTS the stipulation and finds good cause to
continue the date.

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STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER - 3

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Accordingly, IT IS HEREBY ORDERED THAT:

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1. The trial in this matter is continued from May 20, 2014 to January 21, 2015 at
8:30 a.m.;

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2. That the pretrial conference be continued to December 11, 2014, at 8:30 a.m.

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IT IS SO ORDERED.
Dated:

June 18, 2014
SENIOR DISTRICT JUDGE

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PROOF OF SERVICE

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STATE OF CALIFORNIA, COUNTY OF KERN

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I am employed in the County of Kern, State of California. I am over the age of 18
and not a party to the within action; my business address is 2020 Eye Street, Bakersfield,
California 93301

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STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER - 4

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On June , 2014, I served the foregoing document described as follows:

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X

by placing the true copies thereof
by placing the original

addressed as follows:

SEE ATTACHED SERVICE LIST

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X BY MAIL - I enclosed such document in a sealed envelope and caused such
envelope to be deposited in the mail at Bakersfield, California. The envelope was mailed
with postage thereon fully prepaid. I am “readily familiar” with this firm’s practice of
collection and processing of correspondence for mailing. It is deposited with the U.S.
Postal Service on that same day in the ordinary course of business. I am aware that on
motion of party, service is presumed invalid if postal cancellation date or postage meter date
is more than one day after date of deposit for mailing affidavit.
BY OVERNIGHT DELIVERY - I enclosed such document in a sealed envelope
and caused it to be deposited in a box or other facility regularly maintained by the express
service carrier, or delivered to an authorized courier or driver authorized by the express
service carrier to receive documents, in an envelope or package designated by the express
service carrier with delivery fees paid or provided for, addressed to the person on whom it is
to be served, at the office address as last given by that person.
BY FACSIMILE - I caused such document to be transmitted to a facsimile machine
maintained by the person on whom it is served at the facsimile machine telephone number
as last given by that person.

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BY PERSONAL SERVICE - I enclosed such document in a sealed envelope and
caused it to be delivered by hand to the offices of the addressee(s).

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Executed on June , 2014 at Bakersfield, California.
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X_ (Federal) I declare under penalty of perjury under the laws of the United States
that the above is true and correct.

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STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER - 5

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_____________________________________
PATRICK BENITEZ

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PROOF OF SERVICE LIST
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Michael G. Marderosian, Esq.
Heather S. Cohen, Esq.

ATTORNEYS FOR DEFENDANTS:
CITY OF BAKERSFIELD,

STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER - 6

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MARDEROSIAN, RUNYON,
CERCONE & COHEN
1260 Fulton Mall
Fresno, CA 93721

CHRISTOPHER DALTON, and
GREG WILLIAMSON

Virginia Gennaro, Esq.
City Attorney
CITY OF BAKERSFIELD
1501 Truxtun Avenue
Bakersfield, CA 93301

ATTORNEY FOR DEFENDANTS:
CITY OF BAKERSFIELD,
CHRISTOPHER DALTON, and
GREG WILLIAMSON

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STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER - 7