Dora, Jr. et al v. County of Kern et al

Filing 22

Stipulation for Partial Dismissal of Case, Including All Claims of Jaime Alatorre, Raul Alatorre, Gloria Ramirez, David Ramirez, Alexandra Ramirez, and Andrea Ramirez Against Defendants County of Kern, Tanner Miller, and Robert Reed; ORDER, signed by District Judge Lawrence J. O'Neill on 7/13/2015. (Marrujo, C)

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THERESA A. GOLDNER, COUNTY COUNSEL
By: Marshall S. Fontes, Deputy (SBN 139567)
Kern County Administrative Center
1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
Telephone [phone]
Fax [phone]
Attorneys for Defendants
County of Kern, Tanner Miller,
and Robert Reed

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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BRIAN DORA, JR., BRIAN DORA, SR.,
JAIME ALATORRE, RAUL
ALATORRE, GLORIA RAMIREZ,
DAVID RAMIREZ, ALEXANDRA
RAMIREZ AND ANDREA RAMIREZ,
Plaintiffs,

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v.

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COUNTY OF KERN, ROBERT REED,
TANNER MILLER and DOES 1 to 100,
inclusive,

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CASE NO.:
1:14-CV-00896-LJO-JLT
STIPULATION FOR PARTIAL
DISMISSAL OF CASE,
INCLUDING ALL CLAIMS OF
JAIME ALATORRE, RAUL
ALATORRE, GLORIA RAMIREZ,
DAVID RAMIREZ, ALEXANDRA
RAMIREZ A ND ANDREA
RAMIREZ AGINST
DEFENDANTS COUNTY OF
KERN TANNER MILLER AND
ROBERT REED; ORDER

Defendants.

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Trial date:
Time:
Courtroom:

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Complaint filed: June 11, 2014

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June 7, 2016
9:00 a.m.
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Stipulation for Partial Dismissal

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COME NOW, Plaintiffs Gloria Ramirez, David Ramirez, Alexandra

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Ramirez, Andrea Ramirez, Raul Alatorre and Jaime Alatorre, (hereinafter

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“Stipulating Plaintiffs”) through their counsel of record John A. Tello, of the Law

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Firm of Rodriguez and Associates, and Defendants County of Kern, Tanner Miller

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and Robert Reed (hereinafter collectively “County Defendants”) through their

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counsel of record Marshall S. Fontes of Kern County Counsel’s Office, and

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provide as follows:

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IT IS HEREBY STIPULATED, by and between the STIPULATING

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PLAINTIFFS and the COUNTY DEFENDANTS in this action through their

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designated counsel, that any and all claims of the STIPULATING PLAINTIFFS

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in above-captioned action be dismissed with prejudice in their entirety as to any

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complaint, allegation and/or cause of action held by the STIPULATING

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PLAINTIFFS against the COUNTY DEFENDANTS, and more specifically that

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dismissal may be entered in favor of the COUNTY DEFENDANTS and against

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each of the STIPULATING PLAINTIFFS

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IT IS FURTHER STIPULATED that the aforementioned dismissal is in

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consideration of a resolution of the matter by the STIPULATING PLAINTIFFS

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and the COUNTY DEFENDANTS, and that each of said parties hereby agree to

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bear all of its/their own costs and attorney’s fees with respect to the litigation.

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IT IS FURTHER STIPULATED that the aforementioned dismissal and

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agreement will have no effect on nor prejudice against the non-settling plaintiffs,

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Brian Dora, Sr. and Brian Dora, Jr, and their claims against the COUNTY

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DEFENDANTS

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Dated: July 6, 2015

RODRIGUEZ AND ASSOCIATES

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By: /s/ John A. Tello
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John A. Tello, Esq.
Attorney for Plaintiffs, Brian Dora, Jr.,
Brian Dora, Sr., Gloria Ramirez, David
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Stipulation for Partial Dismissal

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Ramirez, Alexandra Ramirez, Andrea
Ramirez, Raul Alatorre and Jaime Alatorre

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Dated: July 9, 2015

THERESA A. GOLDNER, COUNTY COUNSEL

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By: /s/ Marshall S. Fontes
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Marshall S. Fontes, Deputy
Attorneys for Defendants, County of Kern,
Robert Reed and Tanner Miller

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ORDER

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IT IS SO ORDERED.
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Dated:

July 13, 2015

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

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Stipulation for Partial Dismissal