Martinez, et al., v. SCC Florin Road Bingo, et al.,

Filing 34

STIPULATION and ORDER 32 signed by Judge Garland E. Burrell, Jr. on 7/14/11; The parties have leave to ask Magistrate Judge Gregory G. Hollows if he is willing to schedule a settlement conference in this case; Judge Hollows has discretion to ignore the parties request and to decide whether and/or when to schedule anything in this case. (Matson, R)

1 PAUL L. REIN, Esq. (SBN 43053)

CELIA McGUINNESS, Esq. (SBN 159420)

2 CATHERINE M. CABALO, Esq. (SBN 248198)

LAW OFFICES OF PAUL L. REIN

3 200 Lakeside Drive, Suite A

Oakland, CA 94612

4 Telephone: [phone]

Facsimile: 510/832-4787

5

Attorneys for Plaintiffs

6 CONNIE MARTINEZ and

JOSE MARTINEZ

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8 * List of Defendants and their respective counsel listed after the caption.

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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CONNIE MARTINEZ and

CASE NO. 2:10-cv-01647 GEB-GGH
Civil Rights

12 JOSE MARTINEZ,

Plaintiffs,

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14 v.

STIPULATION AND ORDER RE
SETTLEMENT CONFERENCE

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16 SCC FLORIN ROAD BINGO;

SACRAMENTO CONSOLIDATED

17 CHARITIES; KEVIN BEERS;

SHAWN MARTINEZ; ARC

18 PROPERTIES, INC.; AND DOES

1-10, INCLUSIVE,

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Defendants.

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/

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22 SCOTT E. COFER, Esq.

GREVE, CLIFFORD, WENGEL & PARAS, LLP

23 2870 Gateway Oaks Drive, Suite 210

Sacramento, CA 95833

24 Telephone: [phone]

Facsimile: 916/441-7457

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Attorneys for Defendants

26 SCC FLORIN ROAD BINGO, SACRAMENTO

CONSOLIDATED CHARITIES, KEVIN BEERS,

27 AND SHAWN MARTINEZ
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L A W O F F IC E S O F

PAUL L. REIN
200 L A K E SID E D R ., S U I T E A
O A K L A N D , C A 94612-3503
[phone]

STIPULATION AND [PROPOSED] ORDER
TO SET SETTLEMENT CONFERENCE
Case No. 2:10-cv-01647 GEB-GGH

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1 MELISSA T. OMANSKY, Esq.

LEWIS, BRISBOIS, BISGAARD & SMITH LLP

2 221 North Figueroa Street, Suite 1200

Los Angeles, CA 90012

3 Telephone: [phone]

Facsimile: 213/250-7900

4

Attorneys for Defendant

5 ARC PROPERTIES, INC.

Plaintiffs CONNIE MARTINEZ and JOSE MARTINEZ and

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7 defendants SCC FLORIN ROAD BINGO; SACRAMENTO CONSOLIDATED
8 CHARITIES; KEVIN BEERS; SHAWN MARTINEZ; ARC PROPERTIES,
9 INC., by and through their respective counsel, jointly stipulate and request
10 through their attorneys of record as follows:

Since a cooperative site inspection of the subject premises on

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12 October 4, 2010, the parties have been working cooperatively to settle injunctive
13 relief aspects of this case, and believe that there is a good likelihood that the
14 assistance of an experienced magistrate judge would contribute to a settlement of
15 all issues of injunctive relief, damages, and attorneys’ fees, litigation expenses,
16 and costs.
17

Based on the above, the parties hereby agree and stipulate to a

18 settlement conference being set in this case before assigned Magistrate Judge
19 Gregory G. Hollows as soon as possible. The parties further stipulate that a
20 representative or representatives of defendant ARC Properties, Inc. with full
21 settlement authority may appear telephonically for any settlement conference set
22 as long as the representative(s) is/are available telephonically for the entire
23 duration of the settlement conference and ARC Properties, Inc.’s counsel is
24 physically present for the settlement conference.
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26

IT IS SO STIPULATED.

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L A W O F F IC E S O F

PAUL L. REIN
200 L A K E SID E D R ., S U I T E A
O A K L A N D , C A 94612-3503
[phone]

STIPULATION AND [PROPOSED] ORDER
TO SET SETTLEMENT CONFERENCE
Case No. 2:10-cv-01647 GEB-GGH

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1 Dated: July 13, 2011

LAW OFFICES OF PAUL L. REIN

2

/s/ Catherine M. Cabalo
By: CATHERINE M. CABALO, Esq.
Attorneys for Plaintiffs
CONNIE MARTINEZ and
JOSE MARTINEZ

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4
5
6
7 Dated: July 13, 2011

GREVE, CLIFFORD, WENGEL &
PARAS, LLP

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/s/ Scott E. Cofer
By: SCOTT E. COFER, Esq.
Attorneys for Defendants
SCC FLORIN ROAD BINGO,
SACRAMENTO CONSOLIDATED
CHARITIES; KEVIN BEERS; SHAWN
MARTINEZ

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11
12
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15 Dated: July 13, 2011

LEWIS, BRISBOIS, BISGAARD &
SMITH LLP

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17

/s/ Melissa T. Omansky
By: MELISSA T. OMANSKY, Esq.
Attorneys for Defendant
ARC PROPERTIES, INC.

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L A W O F F IC E S O F

PAUL L. REIN
200 L A K E SID E D R ., S U I T E A
O A K L A N D , C A 94612-3503
[phone]

STIPULATION AND [PROPOSED] ORDER
TO SET SETTLEMENT CONFERENCE
Case No. 2:10-cv-01647 GEB-GGH

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1

ORDER
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3
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5

The parties have leave to ask Magistrate Judge Gregory G. Hollows
if he is willing to schedule a settlement conference in this case; Judge Hollows has
discretion to ignore the parties’ request and to decide whether and/or when to
schedule anything in this case.

6
7 Dated: July 14, 2011
8
9

GARLAND E. BURRELL, JR.
United States District Judge

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L A W O F F IC E S O F

PAUL L. REIN
200 L A K E SID E D R ., S U I T E A
O A K L A N D , C A 94612-3503
[phone]

STIPULATION AND [PROPOSED] ORDER
TO SET SETTLEMENT CONFERENCE
Case No. 2:10-cv-01647 GEB-GGH

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