Carrasquilla et al v. Tulare County

Filing 7

Parties' Joint Stipulation and ORDER to Continue the Mandatory Scheduling Conference Hearing Date and Extend Time for Filing of Response to the Complaint. Mandatory Scheduling Conference in this matter, currently set for September 22, 2015, is v acated and continued to October 27, 2015, at 09:00 a.m., in Department 8 (BAM) before Judge McAuliffe. Further, the responsive pleading is now due on or before October 1, 2015. signed by Magistrate Judge Barbara A. McAuliffe on 9/17/2015. (Herman, H)

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Raymond P. Boucher
Brian M. Bush
BOUCHER, LLP
Herman Moreno
LAW OFFICES OF HERMEZ MORENO, PC
21600 Oxnard Street, Suite 600
Woodland Hills, CA 91367
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs
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KATHLEEN BALES-LANGE, #094765
County Counsel for the County of Tulare
Judith D. Chapman, #169479
Deputy County Counsel
2900 West Burrel, County Civic Center
Visalia, California 93291
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant County of Tulare

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA – FRESNO

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CARLOS CARRASQUILLA, ALBA LYDA
CARRASQUILLA,
Plaintiffs,

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vs.

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TULARE COUNTY, DOES 1-10, Inclusive
Defendants.

Case Number: 1:15-cv-00740-BAM
PARTIES’ JOINT STIPULATION
AND ORDER TO CONTINUE
THE MANDATORY
SCHEDULING CONFERENCE
HEARING DATE AND EXTEND
TIME FOR FILING OF
RESPONSE TO THE
COMPLAINT
Date: September 22, 2015
Time: 8:30 a.m.
Courtroom: 8
Barbara A. McAuliffe
U.S. Magistrate Judge

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County Counsel
Tulare County
Visalia, California

JOINT STIPULATION

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Plaintiffs, CARLOS CARRASQUILLA and ALBA LYDA CARRASQUILLA by and

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through their attorneys of record and Defendant, TULARE COUNTY, by and through Tulare

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County Counsel, Deputy County Counsel, Judith D. Chapman, stipulate as follows:

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WHEREAS Defendant was served with the Summons and Complaint on August 27, 2015

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and needs time to gather information regarding the Plaintiffs’ claims. In order to meaningfully

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participate in the meet and confer and the scheduling conference and to prepare a proper response to

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the Complaint;

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WHEREAS the parties are required pursuant to Fed. R. Civ. P. (26(f), meet and confer at
least twenty-one (21) days prior to the Mandatory Scheduling Conference, the parties agree that

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counsel for Defendant will be able to meaningfully participate in the conference after she has had

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time to review the case documents and information.

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THEREFORE the parties respectfully request that the time to file a response to the

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Complaint be extended for 15 days and Mandatory Scheduling Conference currently scheduled for

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September 22, 2015 at 9:00 a.m. be continued for a period of 30 days.

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IT IS SO STIPULATED BY THE ATTORNEYS OF RECORD AND NAMED HEREIN.

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Dated: 9-11-2015

LAW OFFICE OF HERMEZ MORENO, PC

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_____/s/___________________
Hermez Moreno, Attorney for
Plaintiffs

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Dated: 09-11-2015
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KATHLEEN BALES-LANGE
County Counsel

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County Counsel
Tulare County
Visalia, California

_____/s/_____________________
Judith D. Chapman, Attorney for
Defendant County of Tulare

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ORDER

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Based on the parties’ Stipulation to extend time to file the responsive pleading and Continue

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Mandatory Scheduling Conference, and good cause appearing, IT IS HEREBY ORDERED that: The

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Mandatory Scheduling Conference in this matter, currently set for September 22, 2015, is vacated

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and continued to October 27, 2015, at 09:00 a.m., in Department 8 before Judge McAuliffe.

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Further, the responsive pleading is now due on or before October 1, 2015.

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IT IS SO ORDERED.

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Dated:

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County Counsel
Tulare County
Visalia, California

September 17, 2015

/s/ Barbara

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE