Garrett et al v. City of Vallejo et al

Filing 63

STIPULATION and ORDER CONTINUING TRIAL signed by Chief Judge Morrison C. England, Jr on 2/11/15. IT IS ORDERED that pursuant to 62 stipulation, and good cause appearing therefor, the trial date presently set for 4/20/15 is vacated and trial is re-set for 3/28/16 at 9:00 a.m. in Courtroom 7 (MCE) before Chief Judge Morrison C. England, Jr. It is further ordered that the Pre-Trial Conference set for 2/19/15 is also continued and rescheduled for 1/28/16 at 2:00 p.m. (Meuleman, A)

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CLAUDIA QUINTANA
City Attorney, SBN 178613
Kelly J. Trujillo
Deputy City Attorney, SBN 244286
City of Vallejo, City Hall
555 Santa Clara Street, Third Floor
P. O. Box 3068
Vallejo, CA 94590
[phone] FAX: [phone]
MARK A. JONES, SBN 96494
KRISTEN K. PRESTON, SBN 125455
JONES & DYER
A Professional Corporation
1800 J Street
Sacramento, California 95811
Telephone: [phone]
Fax: [phone]
Attorneys for Defendants City of Vallejo, Robert Nichelini, Brian Bates and Bobby Knight

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JOHN L. BURRIS, SBN 69888
BENJAMIN NISENBAUM, SBN 222173
Law Offices of John L. Burris
Airport Corporate Centre
7677 Oakport Street, Suite 1120
Oakland, CA 94621
510-839-5200
510-839-3882 (fax)

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
(Sacramento Division)

GEORGIA MAE GARRETT; D.L., a
minor, by and through his guardian ad
litem, HENRY LEONARD; K.L., a minor,
by and through her guardian ad litem,
HENRY LEONARD,
Plaintiffs,

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vs.

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Case No.: 2:05-CV-00387-MCE-DAD
STIPULATION AND ORDER
CONTINUING TRIAL
Current Pre-Trial Conf.: February 19, 2015
Current Trial Date: April 20, 2015

CITY OF VALLEJO, a municipal
corporation; ROBERT NICHELINI, in his
capacity as Chief of Police for the City of
Vallejo; BRIAN BATES, individually and
in his capacity as a police officer for the
City of Vallejo, BOBBY KNIGHT,
individually and in his capacity as a police
officer for the City of Vallejo; and DOES 1
through 25, inclusive,

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Defendants.
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STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL

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All parties to this action stipulate and agree, by and through their respective counsel, as
follows:
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The court scheduled trial in this matter to commence April 20, 2015 and the Pre-

Trial Conference for February 19, 2015.
2.

Trial counsel for plaintiff, Benjamin Nisenbaum, has a conflict with the presently

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scheduled trial date. Plaintiffs’ trial counsel would be unable to participate given the conflict, and

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the parties have agreed that continuance of the trial date is appropriate.

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Accordingly, the parties request that the court vacate the trial date set for April 20, 2015 and
re-set trial for March 28, 2016 at 9:00 a.m. before Chief Judge Morrison C. England.
The parties further request that the court vacate the Pre-Trial Conference set for February

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19, 2015 and re-set the Pre-Trial Conference for January 28, 2016 at 2:00 p.m.

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DATE: February 6, 2015

JONES & DYER

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By: /s/ Kristen K. Preston
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MARK A. JONES
KRISTEN K. PRESTON
Attorneys for Attorneys for Defendants
City of Vallejo, Robert Nichelini,
Brian Bates and Bobby Knight

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DATE: February 6, 2015

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By: /s/ Kelly Trujillo
CLAUDIA QUINTANA
KELLY J. TRUJILLO
Attorneys for Defendants
City of Vallejo, Robert Nichelini,
Brian Bates and Bobby Knight

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CITY ATTORNEY

DATE: February 6, 2015

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LAW OFFICES OF JOHN L. BURRIS

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By: /s/ Benjamin Nisenbaum
BENJAMIN NISENBAUM
Attorneys for Plaintiffs

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STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL

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ORDER

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Pursuant to stipulation, and good cause appearing therefor, the trial date presently set for April

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20, 2015 is vacated and trial is re-set for March 28, 2016, at 9:00 a.m. in Courtroom 7 (MCE) before

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Chief Judge Morrison C. England, Jr. It is further ordered that the Pre-Trial Conference set for February

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19, 2015 is also continued and rescheduled for January 28, 2016 at 2:00 p.m.

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Dated: February 11, 2015

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STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL