Alba v. County of Tulare, California et al

Filing 16

STIPULATION and ORDER GRANTING the parties' request to continue the Initial Scheduling Conference currently set for 2/18/2016 and CONTINUING it to 4/28/2016 at 10:00 AM in Courtroom 10 (EPG) before Magistrate Judge Erica P. Grosjean. Order signed by Magistrate Judge Erica P. Grosjean on 2/9/2016. (Rooney, M)

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William A. Romaine, #126966
Law Office of William A. Romaine
206 West Lacey Blvd. #309
Hanford, CA 93230
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff

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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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DENNIS ALBA,
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Case Number: 1:15-cv-01492-EPG

Plaintiffs,

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vs.

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COUNTY OF TULARE, CALIFORNIA,
TULARE COUNTY SHERIFF’S DEPUTY
RONALD CROUCH, TULARE COUNTY
SHERIFF’S DEPARTMENT, TULARE
COUNTY SHERIFF’S DEPUTY
SERGEANT TORRES, TULARE COUNTY
SHERIFF’S DEPUTY DERRICK HOOD
AND TULARE COUNTY SHERIFF’S
DEPUTY BERTOLDO,

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PARTIES’ JOINT STIPULATION
AND ORDER TO CONTINUE THE
MANDATORY SCHEDULING
CONFERENCE HEARING DATE
Date: February 18, 2016
Time: 9:00 a.m.
Courtroom: 10
Erica P. Grojean
U.S. Magistrate Judge

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County Counsel
Tulare County
Visalia, California

Defendants.
JOINT STIPULATION

Plaintiff, DENNIS ALBA by and through his attorney of record, William A. Romaine
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PARTIES’ JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE MSC HEARING DATE

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and Defendants, COUNTY OF TULARE, CALIFORNIA, TULARE COUNTY SHERIFF’S

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DEPUTY RONALD CROUCH, TULARE COUNTY SHERIFF’S DEPARTMENT,

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TULARE COUNTY SHERIFF’S DEPUTY SERGEANT TORRES, TULARE COUNTY

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SHERIFF’S DEPUTY DERRICK HOOD AND TULARE COUNTY SHERIFF’S DEPUTY

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BERTOLDO, by and through Tulare County Counsel, Deputy County Counsel, Judith D.

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Chapman, stipulate as follows:

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WHEREAS the parties are required pursuant to Fed. R. Civ. P. 26(f), to meet and

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confer at least twenty-one (21) days prior to the Mandatory Scheduling Conference which is

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scheduled for February 18, 2016. Defendants filed a Motion to Dismiss on February 1, 2016

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and hearing on the Motion to Dismiss has been set for March 11, 2016 at 10:00 a.m. The

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Plaintiff’s Opposition to the Motion Dismiss is due February 26, 2016 and Defendants’

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Reply to Opposition is due March 4, 2016. The parties agree that a Scheduling Conference

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will be more productive and the parties will be able to discuss facts, issues and dates if the

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Scheduling Conference is continued until after the hearing on the Motion to Dismiss.

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THEREFORE the parties respectfully request that the Mandatory Scheduling

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Conference currently scheduled for February 18, 2016 at 9:00 a.m. be continued for a period

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of at least 45 days from the hearing on the Motion to Dismiss, or on or after April 26, 2016.

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IT IS SO STIPULATED BY THE ATTORNEYS OF RECORD AND NAMED

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HEREIN.

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Dated: 2-9-2016

LAW OFFICE OF WILLIAM A. ROMAINE

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____/s/ William A. Romaine______

William A. Romaine, Attorney for
Plaintiff

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Dated: 2-9-2016

KATHLEEN BALES-LANGE
County Counsel

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_____/s/Judith D. Chapman___

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Judith D. Chapman, Attorney for
Defendants

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County Counsel
Tulare County
Visalia, California

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PARTIES’ JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE MSC HEARING DATE

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ORDER
Based on the parties’ Stipulation to continue Mandatory Scheduling Conference, and

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

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Conference in this matter, currently set for February 18, 2016, is vacated and continued to

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April 28, 2016, at 10:00 a.m., in Department 10.

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IT IS SO ORDERED.
Dated:

February 9, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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County Counsel
Tulare County
Visalia, California

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PARTIES’ JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE MSC HEARING DATE