D.G., et al v. County of Kern

Filing 77

STIPULATION AND ORDER signed by District Judge John A. Mendez on 4/21/2017 ORDERING Settlement/Dismissal documents due by 5/19/2017. (Reader, L)

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MARK L. NATIONS, INTERIM COUNTY COUNSEL
By: ANDREW C. THOMSON, DEPUTY (SBN 149057)
Kern County Administrative Center
1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
Telephone [phone]
Fax [phone]
Attorneys for Defendants County
of Kern and Deputy Reed

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
)
D.G., a minor, by and through his
)
guardian ad litem, Denise Bonilla,
individually and as successor-in-interest )
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to David Garcia, deceased; D.E.G., a
minor, by and through her guardian ad )
litem, Denise Bonilla, individually and )
as successor-in-interest to David Garcia, )
)
deceased; G.D., a minor, by and
through her guardian ad litem, Denise )
Bonilla, individually and as successor- )
in-interest to David Garcia, deceased; )
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RAMONA RAMIREZ NUNEZ,
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individually;
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Plaintiffs,
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vs.
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COUNTY OF KERN; DOES 1
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THROUGH 10;
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Defendants.
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CASE NO. 1:15-CV-00760 JAM-JLT
STIPULATION FOR EXTENSION OF TIME
TO FILE SETTLEMENT /DISMISSAL
DOCUMENTS

COME NOW the Parties in this matter, and present this Stipulation for Extension of
time to File Settlement/Dismissal Documents.

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Plaintiffs, D.G., a minor; D.E.G., a minor; G.D., a minor; by and through their guardian

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ad litem Denise Bonilla; and Ramona Ramirez Nunez, (hereinafter collectively “Plaintiffs”) are

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jointly represented by Matthew C. Clark and Neil K. Gehlawat of Chain-Cohn-Stiles, and

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Dale K. Galipo of the Law Offices of Dale K. Galipo.
______________________________________________________________________________________ ________________

Stipulation for Extension of time to File Settlement/Dismissal Documents.
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Defendants, County of Kern (hereinafter “County”) and Deputy Robert Reed

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(hereinafter “Reed”), (hereinafter collectively “Defendants”) are represented by Andrew C.

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Thomson, Office of Kern County Counsel.

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Plaintiffs and Defendants are hereinafter collectively referred to as the “Parties.”

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IT IS HEREBY STIPULATED: The Parties have, and continue to, diligently

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attempted to secure the necessary closing documents and timely arrange annuity payments for

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the minors. A Release and Settlement Agreement has been prepared by Defendants and

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executed by Plaintiffs’ and their counsel. Plaintiffs’ counsel is preparing the minors’

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compromises, with the annuity information, for the court’s approval.

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IT IS RESPECTFULLY REQUESTED: that the Court issue an Order modifying the

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Minute Order [Doc. 75] to extend the date for filing of the Settlement/Dismissal documents, by

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four (4) weeks to May 19, 2017.

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Dated: April 21, 2017

CHAIN-COHN-STILES

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By /s/ Neil K. Gehlawat
Matthew C. Clark
Neil K. Gehlawat
Attorneys for Plaintiffs 

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_

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Dated: April 21, 2017

MARK L. NATIONS, INTERIM COUNTY COUNSEL

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By /s/ Andrew C. Thomson
Andrew C. Thomson, Deputy
Attorneys for Defendants County of
Kern and Deputy Reed

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_

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IT IS SO ORDERED.
Dated: April 21, 2017

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/s/ John A. Mendez________________________
HON. JOHN A. MENDEZ
UNITED STATES DISTRICT COURT JUDGE

#2365518

______________________________________________________________________________________ ________________

Stipulation for Extension of time to File Settlement/Dismissal Documents.
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