Johnson et al v. The City of Vallejo et al

Filing 23

STIPULATION and ORDER re consent to be bound by ProtectiveOrder 13 signed by Judge John A. Mendez on 4/23/14. (Kaminski, H)

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CLAUDIA QUINTANA
City Attorney, SBN 178613
BY: KELLY J. TRUJILLO
Deputy City Attorney, SBN 244286
CITY OF VALLEJO, City Hall
555 Santa Clara Street, P.O. Box 3068
Vallejo, CA 94590
Tel: [phone]
Fax: [phone]
MARK A. JONES, SBN 96494
KRISTEN K. PRESTON, SBN 125455
JONES & DYER
A Professional Corporation
1800 J Street
Sacramento, CA 95811
Tel: [phone]
Fax: [phone]

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Attorneys for Defendants City of Vallejo, Officer Dustin B. Joseph,
Officer Sean G. Kenney and Vallejo Chief of Police Joseph M. Kreins

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IN THE UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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JOSEPH L. JOHNSON, an individual,
CYNTHIA A. MITCHELL, an individual,
and as successor-in-interest and personal
representative of decedent MARIO D.S.M.
ROMERO,

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Plaintiffs,

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THE CITY OF VALLEJO, a municipality
and charter city, POLICE OFFICER
DUSTIN B. JOSEPH, an individual,
POLICE OFFICER SEAN G. KENNEY,
an individual, VALLEJO CHIEF OF
POLICE JOSEPH M. KREINS, an
individual and DOES 1-5, inclusive,

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STIPULATION AND ORDER
REGARDING CONSENT TO BE BOUND
BY PROTECTIVE ORDER

vs.

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Case No.: 2:13-CV-01072-JAM-KJN
(Consolidated with Case No.: 2:13-CV02060-JAM-KJN)

Defendants.

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AND CONSOLIDATED ACTIONS

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STIPULATION AND ORDER REGARDING CONSENT TO BE BOUND BY PROTECTIVE
ORDER

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On November 25, 2013, pursuant to the Stipulation for Protective Order submitted by

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counsel for plaintiffs Joseph Johnson and Cynthia Mitchell and counsel for defendants, the court

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issued a protective order in case number 2:13-CV-01072-JAM-KJN (Docket No. 13).

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On February 24, 2014, the court issued an order consolidating case number 2:13-CV-01072JAM-KJN with 2:13-CV-02060-JAM-KJN for all purposes.

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IT IS HEREBY STIPULATED by and between the parties to the consolidated action that

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Plaintiffs NXXXXXX RXXXXX, a minor, by and through her guardian ad litem, NATASHA

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STEPHENS, individually and Successor in Interest to Decedent MARIO ROMERO; CYNQUITA

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MARTIN, individually and as guardian ad litem for DXXXXX MXXXXX, and DXXXXX

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MXXXXX, both minors,; AHN KHE HARRIS, individually; and AHN LOC HARRIS,

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individually, by and through their attorneys of record, are bound by the aforementioned Protective

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Order (Docket No. 13) as if these parties and their attorneys of record had originally stipulated

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thereto.

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DATE: April 22, 2014

THE HALEY LAW OFFICES, P.C.

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By: /s/ Matthew D. Haley
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MATTHEW D. HALEY
FULVIO F. CAJINA
Attorneys for Plaintiffs NXXXXXX
RXXXXX, a minor, by and through her
guardian ad litem, NATASHA STEVENS,
individually and Successor in Interest to
Decedent MARIO ROMERO, CYNQUITA
MARTIN, individually and as guardian ad
litem for DXXXXX MXXXXX and DXXXXX
MXXXXX, both minors, AHN KHE HARRIS,
individually, and AHN LOC HARRIS,
individually

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STIPULATION AND ORDER REGARDING CONSENT TO BE BOUND BY PROTECTIVE
ORDER

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DATE: April 22, 2014

LAW OFFICES OF CATHERINE HALEY

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By:
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DATE: April 22, 2014

/s/ Catherine Haley
CATHERINE HALEY
Attorneys for Plaintiffs NXXXXXX
RXXXXX, , a minor, by and through her
guardian ad litem, NATASHA STEVENS,
individually and Successor in Interest to
Decedent MARIO ROMERO, CYNQUITA
MARTIN, individually and as guardian ad
litem for DXXXXX MXXXXX and DXXXXX
MXXXXX, both minors, AHN KHE HARRIS,
individually, and AHN LOC HARRIS,
individually

CITY OF VALLEJO ATTORNEY

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By: /s/ Kelly J. Truijillo
CLAUDIA QUINTANA
KELLY J. TRUJILLO
Attorneys for Defendants City of
Vallejo, Officer Dustin B. Joseph,
Officer Sean G. Kenney and Vallejo
Chief of Police Joseph M. Kreins

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DATE: April 21, 2014

JONES & DYER

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By: /s/ Mark A. Jones
MARK A. JONES
KRISTEN K. PRESTON
Attorneys for Defendants City of
Vallejo, Officer Dustin B. Joseph,
Officer Sean G. Kenney and Vallejo
Chief of Police Joseph M. Kreins

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STIPULATION AND ORDER REGARDING CONSENT TO BE BOUND BY PROTECTIVE
ORDER

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ORDER

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IT IS SO ORDERED
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DATED: April 23, 2014
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/s/ John A. Mendez____________
John A. Mendez
U. S. DISTRICT COURT JUDGE

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STIPULATION AND ORDER REGARDING CONSENT TO BE BOUND BY PROTECTIVE
ORDER