Estate of Jessie Paul Contreras et al v. County of Glenn et al

Filing 47

STIPULATION AND ORDER signed by Judge John A. Mendez on 2/28/2012 ORDERING 46 The dismissal in this matter shall be filed within 45 days of the Court's ruling on the Minor's Compromise.(Reader, L) Modified on 2/28/2012 (Reader, L).

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RICHARD J. MOLIN (SBN 066894)
EDWARD V. RIZZUTO (SBN 250930)
STEWART HUMPHERYS
MOLIN & GRIFFITH, LLP
Post Office Box 720
Chico, California 95927
[phone]
Fax: [phone]

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DANIEL E. WILCOXEN (SBN 054805)
E. S. DEACON (SBN 127638)
WILCOXEN CALLAHAM, LLP
2114 K Street
Sacramento, California 95816
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
2114 K Street, Sacramento, California 95816

WILCOXEN CALLAHAM, LLP ,

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ESTATE OF JESSIE P. CONTRERAS, by
and through his Special Administrator,
LEONOR CONTRERAS; LEONOR
CONTRERAS, mother of JESSIE P.
CONTRERAS, deceased, individually; and
JANINE ARLETTE LAUREANA
ARANDA, a Minor, daughter of JESSIE P.
CONTRERAS, deceased, individually, by
and through her guardian ad-litem,
SHANNON GRIFFITH,

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Case No. 2:09-CV-02468-JAM-EFB
STIPULATION AND ORDER
REGARDING DISMISSAL

Plaintiffs,
-v-

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COUNTY OF GLENN; GLENN COUNTY
SHERIFF’S DEPARTMENT; LARRY
JONES, LT. TIM ASBURY, LT.
REVOLINSKI, LT. WARREN, SGT.
WHITE, DEE DEE NELSON, AND E.
CHAVEZ, individually; GLENN MEDICAL
CENTER, INC., and DOES 1 to 50,
Inclusive;
Defendants.
________________________________/

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00046916

STIPULATION AND PROPOSED ORDER REGARDING DISMISSAL

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The parties herein stipulate that the dismissal in this matter will be filed within 45 days of the
Court’s ruling on the Minor’s Compromise.

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DATED: February 23, 2012.

WILCOXEN CALLAHAM, LLP

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By:
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__/s/ - E. S. Deacon________________________
E. S. DEACON # 127638
Attorneys for Plaintiffs ESTATE OF JESSIE P.
CONTRERAS, by and through his Special
Administrator, LEONOR CONTRERAS;
LEONOR CONTRERAS, mother of JESSIE P.
CONTRERAS, deceased, individually; and
JANINE ARLETTE LAUREANA ARANDA,
a Minor, daughter of JESSIE P. CONTRERAS,
deceased, individually, by and through her
guardian ad-litem, SHANNON GRIFFITH

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DATED: February 23, 2012.

STEWART HUMPHERYS
MOLIN & GRIFFITH, LLP

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By:

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__/s/ - Richard Molin_______________________
Richard Molin # 066894
Attorneys for Plaintiffs ESTATE OF JESSIE P.
CONTRERAS, by and through his Special
Administrator, LEONOR CONTRERAS;
LEONOR CONTRERAS, mother of JESSIE P.
CONTRERAS, deceased, individually; and
JANINE ARLETTE LAUREANA ARANDA,
a Minor, daughter of JESSIE P. CONTRERAS,
deceased, individually, by and through her
guardian ad-litem, SHANNON GRIFFITH

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DATED: February 23, 2012.

LAW OFFICES OF DENNIS HALSEY

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By:
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__/s/ - Dennis Halsey______________________
Dennis Halsey
Attorneys for Defendants, TIMOTHY
ASBURY, RICHARD WARREN, PHILIP
REVOLINSKY, HAROLD WHITE, DEE DEE
NELSON, AND EMMANUEL CHAVEZ
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00046916

STIPULATION AND PROPOSED ORDER REGARDING DISMISSAL

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DATED: February 23, 2012.

LAW OFFICES OF LEONARD G. KRUP

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By:

__/s/ - Leonard G. Krup__________________
Leonard G. Krup
Attorneys for Defendants, COUNTY OF
GLENN, GLENN COUNTY SHERIFF’S
DEPARTMENT, AND SHERIFF LARRY
JONES

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DATED: February 23, 2012.

SCHUERING ZIMMERMAN & DOYLE, LLP

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By:

__/s/ - Robert Zimmerman_________________
Robert H. Zimmerman
Attorneys for Defendant GLENN MEDICAL
CENTER, INC.

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ORDER

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IT IS SO ORDERED:

The dismissal in this matter shall be filed within 45 days of the

Court’s ruling on the Minor’s Compromise.

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/s/ John A. Mendez
UNITED STATES DISTRICT COURT JUDGE,
EASTERN DISTRICT OF CALIFORNIA

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00046916

STIPULATION AND PROPOSED ORDER REGARDING DISMISSAL

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Estate of Jessie P. Contreras v. County of Glenn, et al.

2:09-CV-02468-JAM-EFB

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PROOF OF SERVICE

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I am a citizen of the United States, and employed in the County of Sacramento. I am over the age
of eighteen (18) years, and not a party to the within above-entitled action. My business address is
2114 K Street, Sacramento, CA 95816. I served:

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STIPULATION AND PROPOSED ORDER REGARDING DISMISSAL

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on each party listed hereinbelow, via the following method:
Robert H. Zimmerman, Esq.
Schuering Zimmerman & Doyle, LLP
400 University Avenue
Sacramento, California 95825-6502
916-567-0400
F: 916-568-0400
[e-mail]
Attorneys for Defendant GLENN MEDICAL
CENTER, INC.

Richard J. Molin, Esq.
Stewart Humperys Molin & Griffith, LLP
Post Office Box 720
Chico, California 95927
[phone]
F: [phone]
[e-mail]
Co-Counsel and Attorneys for Plaintiffs,
ESTATE OF JESSIE P. CONTRERAS, by
and through his Special Administrator,
LEONOR CONTRERAS; LEONOR
CONTRERAS, mother of JESSIE P.
CONTRERAS, deceased, individually; and
JANINE ARLETTE LAUREANA ARANDA,
a Minor, daughter of JESSIE P.
CONTRERAS, deceased, individually, by and
through her guardian ad litem, SHANNON
GRIFFITH

Leonard G. Krup, Esq.
Attorney at Law
510 W. Wood Street
Willows, California 95988
[phone]
F: [phone]
[e-mail]
Attorney for Defendants COUNTY OF GLENN,
GLENN COUNTY SHERIFF’S DEPARTMENT,
AND SHERIFF LARRY JONES

Dennis Halsey, Esq.
Law Offices of Dennis Halsey
9 Highland Circle
Chico, California 95926
[phone]
No fax number.
[e-mail]
Attorney for Defendants TIMOTHY
ASBURY, PHILIP REVOLINSKY,
RICHARD WARREN, HAROLD WHITE,
DEE DEE NELSON, AND EMMANUEL
CHAVEZ

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_XXX_ Via U.S. Postal Service. By depositing for collection and mailing, following ordinary business practices (I
am familiar with the business practices of the law offices of W ilcoxen Callahan Montgomery & Deacon for collecting
and processing mail, and know that the mail in said office is collected and processed so that this piece of mail was
deposited with the United States Postal Service on the same date indicated hereinbelow), a true copy thereof enclosed
in a sealed envelope with postage thereon fully prepaid.

I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed on February 27, 2012, at Sacramento, California.
___/s/ Holly Mills___________________
Holly Mills

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00046916

STIPULATION AND PROPOSED ORDER REGARDING DISMISSAL