Espinoza v. California Highway Patrol et al
Filing
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STIPULATION and ORDER Continuing the Mid Discovering Status Conference currently set for 4/10/2017 to 5/8/2017 at 08:30 AM in Bakersfield, 510 19th Street before Magistrate Judge Jennifer L. Thurston, signed by Magistrate Judge Jennifer L. Thurston on 3/31/2017. (Kusamura, W)
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LAYFIELD & BARRETT, APC
Joseph M. Barrett, Esq. (SBN 143974)
2 633 West 5th Street, Suite 3300
Los Angeles, CA 90071
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Facsimile: (800) 644-9861
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Attorneys for Plaintiff,
ERNEST J. ESPINOZA, an individual
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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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Telephone: (844) 993-3743; Facsimile: (800) 644-9861
LAYFIELD & BARRETT, APC
69170 IRVINE CENTER DRIVE, SUITE 100, IRVINE, CA 92618
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ERNEST J. ESPINOZA, an
individual
Plaintiff,
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v.
Case No: 1:16-cv-00193-JLT
ORDER GRANTING STIPULATION TO
CONTINUE THE MID-DISCOVERY
STATUS CONFERENCE
(Doc. 52)
CALIFORNIA HIGHWAY
PATROL, a government entity;
STATE OF CALIFORNIA, a
government entity; CITY OF
BAKERSFIELD, a government
entity; COUNTY OF KERN, a
government entity; OFFICER MATT
A. ASHE, an individual; and DOES
1 through 20, inclusive,
Defendants.
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TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF
RECORD:
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IT IS HEREBY STIPULATED, by and through said parties and their
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counsel of record that the Mid-Discovery Status Conference, presently scheduled for
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April 10, 2017, be continued. Plaintiff has good cause to continue the Mid-
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Discovery Status Conference for the following reasons:
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1. Gregory Peacock was Plaintiff’s counsel of record while at Layfield &
Barrett, APC but is no longer with the firm.
2. Gregory Peacock is erroneously listed with his new firm Bruno | Nalu on
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STIPULATION TO CONTINUE MID-DISCOVERY STATUS CONFERENCE
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the docket of this matter as counsel of record for Plaintiff, however
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Plaintiff’s case never left Layfield & Barrett, APC.
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3. Plaintiff will file concurrently with this stipulation a substitution of attorney
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form from Gregory Peacock to Joseph Barrett of Layfield & Barrett, APC
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to correct the court docket.
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4. Further, Plaintiff was released from incarceration on March 6, 2017.
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5. Since the date of Plaintiff’s release, Plaintiff’s counsel at Layfield &
Telephone: (844) 993-3743; Facsimile: (800) 644-9861
LAYFIELD & BARRETT, APC
Barrett, APC has been unable to locate or communicate with Plaintiff even
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69170 IRVINE CENTER DRIVE, SUITE 100, IRVINE, CA 92618
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after numerous attempts to make contact, including sending letters to
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multiple addresses and calling multiple phone numbers for Plaintiff and his
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family members.
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6. As a result, Plaintiff has been unable to provide verified responses to
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discovery propounded by Defendant.
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7. On March 28, 2017, Plaintiff called Layfield & Barrett, APC and provided
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new contact information.
8. Plaintiff’s counsel has conferred with opposing counsel and all parties
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agree to continue the Mid-Discovery Status Conference and corresponding
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deadline to submit Joint Statement.
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For the reasons above, all parties respectfully request that the court consider
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this stipulation and order that the Mid-Discovery Status Conference be continued, as
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Plaintiff has only recently been able to re-establish contact with counsel and
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Plaintiff’s case is also currently undergoing a referral process.
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STIPULATION TO CONTINUE MID-DISCOVERY STATUS CONFERENCE
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Dated: March 30, 2017
LAYFIELD & BARRETT, APC
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By:___/S/ Joseph Barrett
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Joseph M. Barrett, Esq.
Attorneys for Plaintiff
ERNEST J. ESPINOZA
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Dated: March 30, 2017
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Telephone: (844) 993-3743; Facsimile: (800) 644-9861
LAYFIELD & BARRETT, APC
69170 IRVINE CENTER DRIVE, SUITE 100, IRVINE, CA 92618
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By:___/S/ Kenny Nguyen
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Kenny V. Nguyen, Esq.
Deputy Attorney General
Attorney for Defendant
OFFICER MATT A. ASHE
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[PROPOSED] ORDER
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After giving due consideration to the above stipulation, the Court hereby
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continues the Mid-Discovery Status Conference, currently set for April 10, 2017 to
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May 8, 2017. The report SHALL be filed and lodged at least one week before the
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conference.
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Counsel may appear via teleconference by dialing (888) 557-8511 and entering
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Access Code 1652736 provided they lodge an “Intent to appear telephonically” by
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email to Shall@caed.uscourts.gov at least five days before the hearing.
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IT IS SO ORDERED.
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Dated:
March 31, 2017
/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE
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STIPULATION TO CONTINUE MID-DISCOVERY STATUS CONFERENCE
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