Alba v. County of Tulare, California et al

Filing 9

Parties' Joint STIPULATION and ORDER to Continue the Mandatory Scheduling Conference Hearing Date and Extend Time for Filing of Response to the Complaint signed by Magistrate Judge Erica P. Grosjean on 12/28/2015. Initial Scheduling Conference currently set for 1/14/2016 is CONTINUED to 2/18/2016 at 09:00 AM in Courtroom 10 (EPG) before Magistrate Judge Erica P. Grosjean. (Martinez, A)

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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

KATHLEEN BALES-LANGE, #094765
County Counsel for the County of Tulare
7 Judith D. Chapman, #169479
Deputy County Counsel
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2900 West Burrel, County Civic Center
9 Visalia, California 93291
Telephone: [phone]
10 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,

Case Number: 1:15-cv-01492-GSA

Plaintiffs,
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vs.
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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Defendants.

JOINT STIPULATION

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County Counsel
Tulare County
Visalia, California

Date: January 14, 2016
Time: 9:00 a.m.
Courtroom: 10
Erika J. Grosjean
U.S. Magistrate Judge

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PARTIES’ JOINT STIPULATION
AND ORDER TO CONTINUE THE
MANDATORY SCHEDULING
CONFERENCE HEARING DATE
AND EXTEND TIME FOR FILING
OF RESPONSE TO THE
COMPLAINT

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Plaintiff, DENNIS ALBA by and through his attorneys of record and Defendants, COUNTY

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OF TULARE, CALIFORNIA, TULARE COUNTY SHERIFF’S DEPUTY RONALD CROUCH,

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TULARE COUNTY SHERIFF’S DEPARTMENT, TULARE COUNTY SHERIFF’S DEPUTY

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SERGEANT TORRES, TULARE COUNTY SHERIFF’S DEPUTY DERRICK HOOD AND

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TULARE COUNTY SHERIFF’S DEPUTY BERTOLDO , by and through Tulare County Counsel,

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

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WHEREAS Defendant was served with the Summons and Complaint on December 15, 2015

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and needs time to gather information regarding the Plaintiff’s 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;
WHEREAS the parties are required pursuant to Fed. R. Civ. P. 26(f), to meet and confer at

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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 18 days and Mandatory Scheduling Conference currently scheduled for

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January 14, 2016 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: _12/23/15_________

LAW OFFICE OF WILLIAM A. ROMAINE

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________/s/_________________
William A. Romaine, Attorney for
Plaintiff

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Dated: _12/23/15_________

KATHLEEN BALES-LANGE
County Counsel

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

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County Counsel
Tulare County
Visalia, California

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ORDER
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 January 14, 2016, is vacated and

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continued to February 18, 2016 at 9:00 a.m., in Department 10. Further, the responsive pleading is

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now due on or before February 1, 2016.

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IT IS SO ORDERED.
Dated:

December 28, 2015

/s/
UNITED STATES MAGISTRATE JUDGE

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County Counsel
Tulare County
Visalia, California

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