Hoffman Brothers Harvesting, Inc. et al v. County of San Joaquin et al

Filing 19

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 3/31/2021 CONTINUING the 6 Motion to Dismiss Hearing to 4/29/2021 at 02:00 PM in Courtroom 2 (TLN) before District Judge Troy L. Nunley. (Coll, A)

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Mark E. Merin (State Bar No. 043849)

LAW OFFICE OF MARK E. MERIN

1010 F Street, Suite 300
Sacramento, California 95814
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
Attorney for Plaintiffs
HOFFMAN BROTHERS HARVESTING, INC.,
PAUL D. HOFFMAN & SONS, RONALD E.
HOFFMAN, and CARL R. HOFFMAN
DEREK P. COLE, Bar No. 204250
[e-mail]
RONALD J. SCHOLAR, Bar No. 187948
[e-mail]
COLE HUBER LLP
2281 Lava Ridge Court, Suite 300
Roseville, California 95661
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
COUNTY OF SAN JOAQUIN,
DAVID KWONG, and JUANITA M. HUERTA

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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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HOFFMAN BROS. HARVESTING, INC., et al.,

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Case No. 2:20-cv-00660-TLN-AC

Plaintiffs,

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vs.

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JOINT STIPULATION TO CONTINUE
HEARING ON MOTION TO DISMISS;
ORDER

COUNTY OF SAN JOAQUIN, et al.,

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Defendants.
Pursuant to E.D. Cal. L.R. 230(f), the parties—Plaintiffs Hoffman Brothers Harvesting, Inc., Paul

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D. Hoffman & Sons, Ronald E. Hoffman, and Carl R. Hoffman (collectively, “Plaintiffs”) and

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Defendants County of San Joaquin, David Kwong, and Juanita M. Huerta (collectively, “Defendants”)—

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submit the following joint stipulation to continue the hearing date on Defendants’ pending motion to

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dismiss (ECF No. 6).
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JOINT STIPULATION TO CONTINUE HEARING ON MOTION TO DISMISS
Hoffman Bros. Harvesting, Inc. v. County of San Joaquin, United States District Court, Eastern District of California, Case No. 2:20-cv-00660-TLN-AC

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STIPULATION
WHEREAS, Defendants’ pending motion to dismiss was originally noticed and scheduled for
hearing on July 23, 2020 (ECF No. 6);
WHEREAS, the parties jointly stipulated to continue the hearing to September 17, 2020 (ECF
No. 8), and the Court granted the stipulation (ECF No. 9);
WHEREAS, the parties jointly stipulated to further continue the hearing to November 12, 2020
(ECF No. 10), and the Court granted the stipulation (ECF No. 11);
WHEREAS, the parties jointly stipulated to further continue the hearing to January 21, 2021
(ECF No. 12), and the Court granted the stipulation (ECF No. 13);
WHEREAS, the parties jointly stipulated to further continue the hearing to February 18, 2021
(ECF No. 14), and the Court granted the stipulation (ECF No. 15); and
WHEREAS, the parties jointly stipulated to further continue the hearing to April 15, 2021 (ECF
No. 16), and the Court granted the stipulation (ECF No. 17); and
WHEREFORE, the parties’ counsel have discussed, and continue to discuss, potential early

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alternative dispute resolution in this case and a further continuance of the hearing date is necessary to

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facilitate these settlement discussions—specifically, the parties have each made and discussed proposals

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to resolve the parties’ dispute and, most recently, continue to discuss and consider counter-proposals; and

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NOW, THEREFORE, the parties agree and stipulate that:

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Defendants’ pending motion to dismiss (ECF No. 6), currently scheduled to be heard before this

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Court on April 15, 2021, shall be CONTINUED to April 29, 2021, at 2:00 p.m.
IT IS SO STIPULATED.
Dated: March 26, 2021

Respectfully Submitted,

LAW OFFICE OF MARK E. MERIN
/s/ Mark E. Merin

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By: __________________________________
Mark E. Merin

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Attorney for Plaintiffs
HOFFMAN BROTHERS HARVESTING, INC.,
PAUL D. HOFFMAN & SONS, RONALD E.
HOFFMAN, and CARL R. HOFFMAN

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JOINT STIPULATION TO CONTINUE HEARING ON MOTION TO DISMISS
Hoffman Bros. Harvesting, Inc. v. County of San Joaquin, United States District Court, Eastern District of California, Case No. 2:20-cv-00660-TLN-AC

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Dated: March 26, 2021

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Respectfully Submitted,
COLE HUBER LLP
/s/ Derek P. Cole
(as authorized on March 26, 2021)
By: __________________________________
Derek P. Cole
Ronald J. Scholar

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Attorneys for Defendants
COUNTY OF SAN JOAQUIN,
DAVID KWONG, and JUANITA M. HUERTA

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ORDER

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GOOD CAUSE APPEARING, the parties’ stipulation is GRANTED.

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Defendants’ pending motion to dismiss (ECF No. 6), currently scheduled to be heard before this

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Court on April 15, 2021, shall be CONTINUED to April 29, 2021, at 2:00 p.m.
IT IS SO ORDERED.
Dated: March 31, 2021

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Troy L. Nunley
United States District Judge

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JOINT STIPULATION TO CONTINUE HEARING ON MOTION TO DISMISS
Hoffman Bros. Harvesting, Inc. v. County of San Joaquin, United States District Court, Eastern District of California, Case No. 2:20-cv-00660-TLN-AC