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

Filing 186

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/24/18, ORDERING that the enforcement of judgment is STAYED until the resolution of any and all post trial motions. Any motion for attorney fees shall be due 28 days from the Court's order deciding 166 Motion to Amend 153 the Judgment. (Kastilahn, A)

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LAW OFFICE OF DALE K. GALIPO
DALE K. GALIPO, SBN 144074
MELANIE T. PARTOW, SBN 254843
21800 Burbank Blvd., Suite 310
Woodland Hills, CA 91367
Telephone: [phone]
Facsimile: [phone]

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LAW OFFICE OF STEWART KATZ
STEWART KATZ, SBN 127425
555 University Avenue, Suite 270
Sacramento, California 95825
Telephone: [phone]
MOSELEY COLLINS LAW
A Professional Law Corporation
MOSELEY C. COLLINS, III, SBN 92460
1180 Iron Point Rd., Suite 180
Folsom, CA 95630
Telephone: [phone]

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Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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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,

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

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
through 10, inclusive,
Defendants.
_________________________________
STIPULATION AND ORDER FOR STAY OF ENFORCEMENT OF JUDGMENT AND TO SET
DEADLINE FOR MOTION TO FILE ATTORNEY FEES
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This stipulation is to supersede and correct a typographical error contained in the

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Stipulation that is Docket No. 162, as well as to clarify the triggering date potentially for

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filing a motion for attorney fees.

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

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

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Karen Rose, individually, are represented by Stewart Katz of the Law Office of Stewart

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

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Galipo of the Law Office of Dale K. Galipo. Defendants County of Sacramento and David

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McEntire (“Defendants”) are represented by Van Longyear of Longyear, O’Dea & Lavra,

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LLP.
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

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motions. The parties do not intend the stipulation to include any time period for any appeal

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of the judgment.

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The parties further stipulate that any motion for attorney fees shall be due 28 days

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from the Court’s order deciding Docket No. 166, which is Defendants’ Notice of Motion

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and Motion for Order Altering/Amending the Judgment to Strike the Award of

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Noneconomic Damages to Plaintiff Theodore Rose, Jr. and/or for Judgment as a Matter of

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Law and/or in the Alternative an Order for a New Trial.

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Dated: April 23, 2018

LAW OFICE OF STEWART KATZ
/s/ Stewart Katz
STEWART KATZ
Attorney for Plaintiffs

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Dated: April 23, 2018

LONGYEAR, O’DEA & LAVRA, LLP
/s/ Van Longyear
VAN LONGYEAR
Attorneys for Defendants

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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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ORDER

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IT IS SO ORDERED.

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Dated: April 24, 2018

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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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