Winn v. County of Kern et al

Filing 24

STIPULATION and ORDER 23 to Continue Settlement Conference, signed by Magistrate Judge Jennifer L. Thurston on 12/28/2017. Settlement Conference CONTINUED to 1/29/2018 at 01:30 PM in Bakersfield, 510 19th Street before Magistrate Judge Jennifer L. Thurston. (Hall, S)

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David J. Frankenberger, #186140
Michael E. Lehman, #133523
ERICKSEN ARBUTHNOT
Attorneys At Law
2440 West Shaw Avenue, Suite 101
Fresno, California 93711
Phone [phone]
Fax [phone]

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Attorneys for Defendant COUNTY OF KERN, LISA GREEN, SCOTT TUNNICLIFFE and
CHARLES BROWN

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UNITED STATES DISTRICT
EASTERN DISTRICT OF CALIFORNIA

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Plaintiffs,
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v.
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COUNTY OF KERN, a municipality; LISA
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GREEN, individually and in her official
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capacity; SCOTT TUNNICLIFFE, individually )
and in his official ,
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Defendant(s).
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JAY WINN,

Case No. 1:16-CV-01021-DAD-JLT

STIPULATION TO CONTINUE
SETTLEMENT CONFERENCE
HEARING; PROPOSED ORDER
(Doc. 23)

The Parties hereby stipulate by and through their respective counsel that the Settlement
Conference currently scheduled for January 4, 2018 be continued to a date set by the court herein.

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This stipulation is based upon the fact that lead counsel for County of Kern recently associated in
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and had to review the file materials provided by the County in order to prepare for the Settlement

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Conference which had been previously scheduled for December 18, 2017. Defendants’ associated

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counsel has now reviewed the file materials, and upon attempting to contact Kern County

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Counsel’s office to discuss the settlement conference, associated counsel learned that the County

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Counsel’s office is closed between December 22, 2017 to January 2, 2018, by an imposed

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STIPULATION TO CONTINUE SETTLEMENT CONFERENCE HEARING; PROPOSED ORDER

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furlough.

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Therefore, associated counsel cannot respond to Plaintiff’s settlement demand, nor can it
submit its settlement conference statement, without further discussion with County Counsel’s

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office. In order to participate in a meaningful settlement conference the parties request that the
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currently scheduled settlement conference be continued to January 29, 2018.

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DATED: December 28, 2017

ERICKSEN ARBUTHNOT

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By /s/ Michael E. Lehman______
Michael E. Lehman
Attorney for Defendants
COUNTY OF KERN, LISA GREEN,
SCOTT TUNNICLIFFE and CHARLES
BROWN

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DATED: December 28, 2017

ADAMS, FERRONE & FERRONE

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By /s/ Michel A. McGill_________
Michael A. McGill
Attorney for
Plaintiff JAY WINN

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__________________________________________________________________

STIPULATION TO CONTINUE SETTLEMENT CONFERENCE HEARING; PROPOSED ORDER

***PROPOSED ORDER***

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For all of the above reasons the settlement conference scheduled for January 4, 2018 is

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hereby moved to January 29, 2018 but at 1:30 p.m. (rather than 9:30) at the United States

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Courthouse at 510 19th Street, Bakersfield, CA.

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IT IS SO ORDERED.
Dated:

December 28, 2017

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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PROOF OF SERVICE

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STATE OF CALIFORNIA

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COUNTY OF FRESNO

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STIPULATION TO CONTINUE SETTLEMENT CONFERENCE HEARING; PROPOSED ORDER

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I am a resident of the County aforesaid; I am over the age of 18 years and not a party to the
within action; my business address is: 2440 West Shaw, Suite 101, Fresno, CA 93711-3300. I am
familiar with the regular mail collection and processing practices of said business, and in the
ordinary course of business the mail is deposited with the United States Postal Service that same
day.
On December 28, 2017, I served the within STIPULATION TO CONTINUE
SETTLEMENT CONFERENCE HEARING; PROPOSED ORDER by placing a true copy
thereof, enclosed in a sealed envelope with postage thereon fully prepaid, in the United States
Mail at Fresno, California, addressed as follows:
Attorney for Plaintiff
Michael A. McGill
Adams, Ferrone & Ferrone
4333 Park Terrace Drive, Suite 200
Westlake Village, California 91361
Fax: [phone]

Attorneys for County of Kern, Lisa Green,
Scott Tunnicliffe and Charles Brown
Mark L. Nations, County Counsel
Andrew Thomson, Deputy County Counsel
Kern County Administrative Center
1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
Fax: [phone]

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I declare under penalty of perjury under the laws of the State of California the above is true
and correct.
Executed on December 28, 2017, at Fresno, California.

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____________________________
Kalyn Stonacek

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STIPULATION TO CONTINUE SETTLEMENT CONFERENCE HEARING; PROPOSED ORDER