Alba v. County of Tulare, California et al

Filing 32

STIPULATION and ORDER GRANTING the stay of all proceedings and vacating all pending deadlines and hearings, including the trial of 10/17/2017. The Court sets a Scheduling Conference for 4/17/2017 at 10:30 AM in Courtroom 10 (EPG) before Magistrate Judge Erica P. Grosjean. Order signed by Magistrate Judge Erica P. Grosjean on 1/30/2017. (Rooney, M)

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1 2 3 4 William A. Romaine, #126966 Law Office of William A. Romaine 206 West Lacey Blvd. #309 Hanford, CA 93230 Telephone: (559) 582-9360 Facsimile: (559) 582-9350 Attorney for Plaintiff 5 11 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 Phone: (559) 636-4950 Fax: (559) 737-4319 E-mail: 12 Attorneys for Defendants 6 7 8 9 10 13 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 14 15 16 DENNIS ALBA, Plaintiff, 17 18 Case Number: 1:15-cv-01492-EPG vs. 19 20 21 22 23 24 25 26 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, STIPULATION TO STAY ENTIRE MATTER, INCLDUING ALL DATES, INCLUDING BUT NOT LIMITED TO DISCOVERY DATES, DISCOVERY DISPUTE DATES, AND ALL OTHER CUT-OFF DATES AND APPEARANCE DATES, AND SET NEW SCHEDULING CONFERENCE; ORDER Trial Date: October 17, 2017 Exempt from Filing Fees Pursuant to Government Code §6103 Defendants. 27 28 County Counsel Tulare County Visalia, California 1 STIPULATION TO STAY PROCEEDINGS 1 THE PARTIES HERETO SIPULATE to request the Court for an Order hereby 2 staying this action in its entirety, including, but not limited to all dates, cut-off dates, discovery 3 dates, and discovery dispute dates and to vacate the trial date currently set for October 17, 2017. 4 The parties further request that the Court set a new Scheduling Conference in this matter at a date 5 and time after March 31, 2017. 6 1. The parties hereby stipulate and agree that good cause exists to stay the proceedings and 7 request the Court to set a new and further Scheduling Conference. The parties agree that a stay is 8 necessary to protect the rights of the parties to fully and fairly litigate this case because Plaintiff’s 9 attorney is currently unavailable due to a serious health condition. Said unavailability is scheduled 10 11 to extend until on or after March 31, 2017. 2. Plaintiff’s attorney of record, William A. Romaine, has authorized Attorney David 12 Douglas Doyle, Bar No. 100595, of the firm of Doyle & Fortune, 1233 W. Shaw Avenue #106, 13 Fresno, California (559) 227-2600 to specially appear and to sign this Stipulation in order to 14 secure the stay in this matter on his behalf. 15 Dated: January 30, 2017 KATHLEEN BALES-LANGE Tulare County Counsel 16 17 18 By___/s/___________________ JUDITH D. CHAPMAN Deputy County Counsel 19 20 21 22 Dated: January 27, 2017 DOYLE & FORTUNE 23 By ___/s/____________________ DAVID D. DOYLE William A. Romaine, Attorney for Plaintiff. 24 25 26 27 28 County Counsel Tulare County Visalia, California 2 STIPULATION TO STAY PROCEEDINGS ORDER 1 2 Good cause appearing, the Court hereby stays the proceedings and vacates all 3 deadlines and dates currently set in this matter, including the trial date currently set for 4 October 17, 2017. Any discovery disputes pending between the parties are hereby also 5 suspended until a new Scheduling Conference may be set by this Court at a date and 6 time after March 31, 2017. 7 The Court sets new Scheduling Conference for April 17, 2017 at 10:30 a.m. in 8 Department 10. The parties shall file a joint scheduling report no later than one week 9 before the Scheduling Conference and shall email a copy of the report to 10 11 12 13 14 IT IS SO ORDERED. Dated: January 30, 2017 /s/ UNITED STATES MAGISTRATE JUDGE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 County Counsel Tulare County Visalia, California 3 STIPULATION TO STAY PROCEEDINGS

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