Arrieta v. County of Kern

Filing 31

STIPULATION and ORDER 30 for Filing Responsive Pleadings in Consolidated Cases, signed by Magistrate Judge Jennifer L. Thurston on 7/14/2014. (Hall, S)

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Leonard C. Herr, #081896
DOOLEY, HERR, PEDERSEN & BERGLUND BAILEY
Attorneys at Law, LLP
100 Willow Plaza, Suite 300
Visalia, California 93291
Telephone: [phone]
Fax: [phone]
Theresa A. Goldner, County Counsel
Andrew C. Thomson, #149057
Deputy County Counsel
OFFICE OF THE COUNTY COUNSEL
COUNTY OF KERN
1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
Telephone: [phone]
Fax: [phone]
Attorneys for Defendant, COUNTY OF KERN

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRANCISCO ARRIETA,

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CASE No.:

Plaintiff,

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v.

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COUNTY OF KERN, and DOES 1 to
100, Inclusive,

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1:14-cv-00400-LJO-JLT

STIPULATION FOR FILING
RESPONSIVE PLEADINGS IN
CONSOLIDATED CASES AND
ORDER THEREON
(Doc. 30)

Defendants.
AND RELATED CONSOLIDATED
CASES
The parties, having met and conferred by and through counsel, do hereby
stipulate to the following schedule for response to the complaint in this matter.
RECITALS

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WHEREAS, the Court has ordered the consolidation for pre-trial purposes

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of all six of the case numbers cited in the caption of this order [referred to here by

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the last three digits of the case numbers]; and,

LAW OFFICES
DOOLEY, HERR,
PEDERSEN &
BERGLUND BAILEY
Attorneys at Law, LLP
100 Willow Plaza
Suite 300
Visalia, CA 93291
[phone]

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STIPULATION FOR FILING RESPONSIVE PLEADINGS IN CONSOLIDATED
CASES AND ORDER THEREON

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WHEREAS, Defendants are, by stipulation, to answer the complaint in Case
no. 717 on or before July 14, 2014; and,
WHEREAS, the Plaintiffs in Case nos. 400-404 are to file an amended
complaint on or before July 15; and,
WHEREAS, the parties agree that a single complaint will best facilitate the

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Court’s order of consolidation for purposes of pre-trial management; then,

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The parties, by and through counsel, agree to the following:

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TERMS AND CONDITIONS
1.

Defendants are relieved of the obligation to file their responsive

pleading to the complaint in Case no. 717 on July 14, 2014.
2.

Plaintiffs will file a single complaint for all six case numbers on or

before July 15, 2014.
3.

Defendants will file a single responsive pleading to the amended

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complaint by all six Plaintiffs within the time to do so set forth by the Federal

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Rules of Civil Procedure.

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4.

While this will be the first amended complaint in Case no. 717, and

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will be treated as such, should an issue arise in which that fact might be relevant,

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the complaint will be titled the second amended complaint for all six cases and

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treated as such for case numbers 400-404.

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5.

Neither this order nor the stipulation giving rise to it shall be read

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with prejudice against or favor for any party’s motion, if one is made, to bifurcate,

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sever, or otherwise undo the Court’s consolidation of these cases.

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LAW OFFICES
DOOLEY, HERR,
PEDERSEN &
BERGLUND BAILEY
Attorneys at Law, LLP
100 Willow Plaza
Suite 300
Visalia, CA 93291
[phone]

Respectfully submitted.
Dated: July 14, 2014

RODRIGUEZ & ASSOCIATES
By:

/s/ Chantal Trujillo
CHANTAL TRUJILLO
Attorney for PLAINTIFFS,
FRANCISCO ARRIETA, MELISSA QUAIR,
SULINA QUAIR, MARIA MELENDEZ,
LAURA VAZQUEZ, and T.A., a minor
by and through his guardian ad litem,
-2MARIA GUERRERO

STIPULATION FOR FILING RESPONSIVE PLEADINGS IN CONSOLIDATED
CASES AND ORDER THEREON

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Dated: July 14, 2014

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By:

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/s/ Leonard C. Herr
LEONARD C. HERR
Attorney for DEFENDANT,
COUNTY OF KERN
ORDER

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DOOLEY HERR PEDERSEN &
BERGLUND BAILEY, LLP

Based upon the stipulation of the parties, the Court ORDERS:
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The stipulation of the parties (Doc. 30) is GRANTED.

IT IS SO ORDERED.
Dated:

July 14, 2014

/s/ Jennifer L. Thurston
UNITED

STATES

MAGISTRATE

JUDGE

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LAW OFFICES
DOOLEY, HERR,
PEDERSEN &
BERGLUND BAILEY
Attorneys at Law, LLP
100 Willow Plaza
Suite 300
Visalia, CA 93291
[phone]

-3STIPULATION FOR FILING RESPONSIVE PLEADINGS IN CONSOLIDATED
CASES AND ORDER THEREON

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F:\Client Files\County of Kern 1534.00\1534.02 - Arrieta v. Co. of Kern(Consolidated)\Pleadings\Stipulation and Order re filing answer re consolidated cases.doc

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LAW OFFICES
DOOLEY, HERR,
PEDERSEN &
BERGLUND BAILEY
Attorneys at Law, LLP
100 Willow Plaza
Suite 300
Visalia, CA 93291
[phone]

-4STIPULATION FOR FILING RESPONSIVE PLEADINGS IN CONSOLIDATED
CASES AND ORDER THEREON