Rose, et al v. County of Sacramento, et al

Filing 162

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 10/20/2017 ORDERING a STAY of enforcement of judgment, without the posting of a bond, through the resolution of any and all post-trial motions. Any motion for attorney fees shall be due by 12/11/2017 or 20 days from the entry of judgment on any post-trial motions, whichever is later. (Zignago, K.)

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LONGYEAR, O’DEA & LAVRA, LLP
Van Longyear, CSB No. 84189
Peter C. Zilaff, CSB No. 272658
3620 American River Drive, Suite 230
Sacramento, CA 95864
Phone: [phone]
Facsimile: [phone]
Attorneys for Defendants COUNTY OF SACRAMENTO, SHERIFF SCOTT JONES,
DEPUTY DAVID McENTIRE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

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Estate of JOHNATHAN ROSE, deceased, by
and through his parents THEODORE
MILTON ROSE and KAREN ROSE, as
successors in interest; THEODORE MILTON
ROSE, Individually; and KAREN ROSE,
Individually,

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Plaintiffs,
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vs.
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COUNTY OF SACRAMENTO; Sacramento )
County Sheriff SCOTT JONES; Sacramento )
County Sheriff’s Department Deputy DAVID )
McENTIRE (Badge #1356); and DOES 1
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through 10, inclusive,
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Defendants.
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Case No. 2:13-cv-01339 TLN EFB
STIPULATION AND ORDER FOR STAY
OF ENFORCEMENT OF JUDGMENT
AND TO SET DEADLINE FOR MOTION
TO FILE ATTORNEY FEES

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Plaintiffs, Estate of Johnathan Rose, by and through his parents Theodore Milton Rose

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and Karen Rose, as successors in interest, Theodore Milton Rose, individually, and Karen Rose,

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individually, are represented by Stewart Katz of the Law Office of Stewart Katz, Moseley C.

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Collins, III of the Law Office of Moseley C. Collins, III and Dale K Galipo of the Law Office of

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Dale K. Galipo. Defendants County of Sacramento and David McEntire (“Defendants”) are

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represented by Van Longyear and Peter Zilaff of Longyear, O’Dea & Lavra, LLP.

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The parties, through their respective attorneys, stipulate to a stay of enforcement of

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judgment, without the posting of a bond, through the resolution of any and all post-trial motions.
STIPULATION AND ORDER FOR STAY OF ENFORCEMENT OF JUDGMENT AND TO SET
DEADLINE FOR MOTION TO FILE ATTORNEY FEES
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The parties do not intend the stipulation to include any time period for any appeal of the

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judgment.

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The parties further stipulate that any motion for attorney fees shall be due by December
11, 2017 or 20 days from the entry of judgment on any post-trial motions, whichever is later.

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Dated: October 19, 2017

LONGYEAR, O’DEA & LAVRA, LLP

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By: /s/ Peter C. Zilaff
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VAN LONGYEAR
PETER C. ZILAFF
Attorneys for Defendants, COUNTY OF
SACRAMENTO, SHERIFF SCOTT
JONES, AND DEPUTY DAVID
McENTIRE

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Dated: October 19, 2017

LAW OFFICE OF DALE K. GALIPO

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By: /s/ Melanie T. Partow
Dale K. Galipo
Melanie T. Partow
Attorneys for Plaintiffs

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ORDER

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IT IS SO ORDERED.
Dated: October 20, 2017

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Troy L. Nunley
United States District Judge

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STIPULATION AND ORDER FOR STAY OF ENFORCEMENT OF JUDGMENT AND TO SET
DEADLINE FOR MOTION TO FILE ATTORNEY FEES
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