Navarrette et al v. United States Of America

Filing 77

ORDER GRANTING 76 Stipulation RE: Request for Conference with the Court. Signed by Judge Jeffrey S. White on 7/9/09. (jjo, COURT STAFF) (Filed on 7/9/2009)

Case3:04-cv-00760-JSW Document76

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BARBARA L. BOZMAN-MOSS (CSBN 129275) Bozman-Moss & Watson 700 College Avenue Santa Rosa, CA 95404 Tel: [phone] Fax: [phone] E-mail: [e-mail] Attorney for Plaintiffs JOSEPH P. RUSSONIELLO (CSBN 44332) United States Attorney JOANN M. SWANSON (CSBN 88143) Chief, Civil Division ELLEN M. FITZGERALD (NY 2408805) Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, CA 94102-3495 Tel: [phone] Fax: [phone] E-mail: [e-mail] Attorneys for Defendant UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) Plaintiffs, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) ) Defendant. ) ____________________________________) RICARDO ANGEL NAVARRETTE and KELLY KASLAR,

Case No. CV 04-0760 JSW STIPULATION AND JOINT REQUEST FOR CONFERENCE WITH THE COURT; [PROPOSED] ORDER

Subject to this Court's approval, plaintiff, Ricardo Angel Navarrette, and defendant, the United States of America, by and through their undersigned counsel, hereby stipulate to and jointly request a conference with the Court on or after August 21, 2009.

STIPULATION AND JOINT REQUEST FOR CONFERENCE WITH THE COURT C 04-0760 JSW

Case3:04-cv-00760-JSW Document76

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This case involves an action for personal injury arising under the Federal Tort Claims Act. On or about April 2, 2009, the parties entered into a settlement agreement and submitted the agreement and a proposed order for the Court's signature. On or about April 3, 2009, the Court entered an order approving the settlement. Thereafter, at the request of plaintiff's counsel, the parties entered into an agreement to amend the terms of the April 2, 2009, settlement agreement. The parties jointly request a conference to inform the Court about this amendment and to seek the Court's approval of the amended settlement agreement. The parties will submit a fully-executed, amended settlement agreement and a proposed order for the Court's review prior to the conference. Plaintiff's counsel will be out-of-the country on vacation from July 7 to August 14, 2009. The parties therefore request that the Court schedule a conference on or after Friday, August 21,

IT IS SO STIPULATED. Dated: July 8, 2009 Respectfully submitted, JOSEPH RUSSONIELLO United States Attorney By: /s/ ELLEN M. FITZGERALD Assistant United States Attorney Attorney for Defendant BOZMAN-MOSS & WATSON

By:

/s/ BARBARA BOZMAN-MOSS Attorney for Plaintiff

STIPULATION AND JOINT REQUEST FOR CONFERENCE WITH THE COURT C 04-0760 JSW

Case3:04-cv-00760-JSW Document76

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APPROVED AND SO ORDERED. 1:30 August 21 The Court hereby schedules a status conference for_____________, 2009 at ___PM.

July 9 DATED: _________, 2009

__________________________ HON. JEFFREY S. WHITE United States District Judge

STIPULATION AND JOINT REQUEST FOR CONFERENCE WITH THE COURT 3 C 04-0760 JSW