Alba v. County of Tulare, California et al
Filing
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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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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
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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
Phone: (559) 636-4950
Fax: (559) 737-4319
E-mail: jchapman@co.tulare.ca.us
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Attorneys for Defendants
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
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DENNIS ALBA,
Plaintiff,
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Case Number: 1:15-cv-01492-EPG
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,
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.
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County Counsel
Tulare County
Visalia, California
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STIPULATION TO STAY PROCEEDINGS
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THE PARTIES HERETO SIPULATE to request the Court for an Order hereby
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staying this action in its entirety, including, but not limited to all dates, cut-off dates, discovery
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dates, and discovery dispute dates and to vacate the trial date currently set for October 17, 2017.
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The parties further request that the Court set a new Scheduling Conference in this matter at a date
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and time after March 31, 2017.
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1. The parties hereby stipulate and agree that good cause exists to stay the proceedings and
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request the Court to set a new and further Scheduling Conference. The parties agree that a stay is
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necessary to protect the rights of the parties to fully and fairly litigate this case because Plaintiff’s
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attorney is currently unavailable due to a serious health condition. Said unavailability is scheduled
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to extend until on or after March 31, 2017.
2. Plaintiff’s attorney of record, William A. Romaine, has authorized Attorney David
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Douglas Doyle, Bar No. 100595, of the firm of Doyle & Fortune, 1233 W. Shaw Avenue #106,
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Fresno, California (559) 227-2600 to specially appear and to sign this Stipulation in order to
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secure the stay in this matter on his behalf.
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Dated: January 30, 2017
KATHLEEN BALES-LANGE
Tulare County Counsel
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By___/s/___________________
JUDITH D. CHAPMAN
Deputy County Counsel
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Dated: January 27, 2017
DOYLE & FORTUNE
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By ___/s/____________________
DAVID D. DOYLE
William A. Romaine, Attorney for
Plaintiff.
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County Counsel
Tulare County
Visalia, California
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STIPULATION TO STAY PROCEEDINGS
ORDER
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Good cause appearing, the Court hereby stays the proceedings and vacates all
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deadlines and dates currently set in this matter, including the trial date currently set for
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October 17, 2017. Any discovery disputes pending between the parties are hereby also
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suspended until a new Scheduling Conference may be set by this Court at a date and
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time after March 31, 2017.
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The Court sets new Scheduling Conference for April 17, 2017 at 10:30 a.m. in
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Department 10. The parties shall file a joint scheduling report no later than one week
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before the Scheduling Conference and shall email a copy of the report to
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epgorders@caed.uscourts.gov.
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IT IS SO ORDERED.
Dated:
January 30, 2017
/s/
UNITED STATES MAGISTRATE JUDGE
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County Counsel
Tulare County
Visalia, California
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STIPULATION TO STAY PROCEEDINGS
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