Canas et al v. County of San Joaquin et al

Filing 15

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 9/28/15 14 ORDERING that the hearing on 11 MOTION to DISMISS is CONTINUED to 11/19/2015 at 02:00 PM in Courtroom 2 (TLN) before District Judge Troy L. Nunley. (Meuleman, A)

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DANIEL MALAKAUSKAS, SBN 265903
P.O. Box 7006
Stockton, CA 95267
Telephone: [phone]
Facsimile: 888-802-2440

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Attorney for Plaintiffs
DANA A. SUNGTAG, SBN 125127
HERUM\CRABTREE\SUNTAG
5757 Pacific Avenue
Suite 222
Stockton, CA 95207
Telephone: [phone]
Facsimile: 209-472-7986
Attorney for Defendants

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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CASE NO.: 2:14-cv-02895-TLN-KJN
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LUZ MARIA CANAS, CARLOS CANAS,
KARLA RIVAS, DARLHA CANAS, THE
ESTATE OF ALEJANDRO GOVEA,
ALEJANDRO GOVEA, CECILIA BAIRES

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Plaintiff,

STIPULATION AND ORDER
REGARDING CONTINUANCE OF
DEFENDANTS’ MOTION TO DISMISS

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v.
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COUNTY OF SAN JOAQUIN, NATALIE
LERMA-SOLIS, in her official and
individual capacities, JORGE CEDANO, in
his official and individual capacities, and
Does 1 through 50, inclusive.
Defendants.
LET THIS HONORABLE COURT TAKE NOTICE:

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Plaintiffs, LUZ MARIA CANAS, CARLOS CANAS, KARLA RIVAS, DARLHA
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CANAS, THE ESTATE OF ALEJANDRO GOVEA, ALEJANDRO GOVEA, and CECILIA
STIPULATION AND ORDER REGARDING CONTINUANCE OF DEFENDANTS’
MOTION TO DISMISS AND ORDER GRANTING THEREOF

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BAIRES, through their attorney, DANIEL MALAKAUSKAS, and Defendants, COUNTY OF
SAN JOAQUIN, NATALIE LERMA-SOLIS, and JORGE CEDANO, through their attorney,

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DANA A. SUNTAG, respectfully report:
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1.

That initially, DANIEL MALAKAUSKAS, attorney for Plaintiffs, was unable to

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attend the initial Motion to Dismiss hearing date on September 24th, 2015. Therefore, on

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September 2nd, 2015, DANIEL MALAKAUSKAS, asked DANA SUNTAG, attorney for

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Defendants, if the Defendants would stipulate to continuing the hearing to a later date.

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2.

The Defendants graciously agreed to stipulate to a continuance. DANA SUNTAG

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advised DANIEL MALAKAUSKAS that the next date DANA SUNTAG would be available

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would be after October 26th, 2015, as he would be on vacation and out of the country until

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October 25, 2015.

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3.

The parties agreed to stipulate to continue the Motion to Dismiss hearing date.

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On September 11th, 2015, the court issued its own minute order continuing the

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hearing date from September 24th, 2015 to October 22nd, 2015.
5.

The parties are unavailable on October 22nd, 2015, and, therefore, stipulate to

continue the hearing date from October 22nd, 2015, to November 19th, 2015, or as soon thereafter

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as may be heard.

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IT IS HEREBY STIPULATED.

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Respectfully Submitted,

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Dated: September 11th, 2015

/s/Daniel Malakauskas________
By: Daniel Malakauskas,
Attorney for Plaintiffs

STIPULATION AND ORDER REGARDING CONTINUANCE OF DEFENDANTS’
MOTION TO DISMISS AND ORDER GRANTING THEREOF

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HERUM\CRABTREE\SUNTAG
A California Professional Corporation

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Dated: September 11th, 2015

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/s/Dana A. Suntag___________________
By: Dana A. Suntag
Attorneys for Defendants
ORDER

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IT IS HEREBY ORDERED, that the motion to dismiss set for October 22nd, 2015 is
continued from October 22nd, 2015 to November 19, 2015.

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Dated: September 28, 2015

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Troy L. Nunley
United States District Judge

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STIPULATION AND ORDER REGARDING CONTINUANCE OF DEFENDANTS’
MOTION TO DISMISS AND ORDER GRANTING THEREOF

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