Alvarez-Orellana v. City of Antioch et al

Filing 44

STIPULATION AND ORDER re 43 Continuing 4.18.13 CMC and Related Rule 26 Disclosures filed by Loren Bledsoe, Allan Cantando, City of Antioch Case Management Statement due by 6/20/2013. Case Management Conference set for 6/27/2013 09:00 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 4/12/13. (bpf, COURT STAFF) (Filed on 4/12/2013)

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Gregory M. Fox, State Bar No. 070876
BERTRAND, FOX & ELLIOT
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
CITY OF ANTIOCH, LOREN BLEDSOE
and ALLAN CANTANDO

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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LUIS A. ALVAREZ-ORELLANA,

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Plaintiff,

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v.

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CITY OF ANTIOCH; LOREN BLEDSOE,
individually and in his capacity as a police
officer for the CITY OF ANTIOCH; ALLAN
CANTANDO, individually and in his official
capacity as chief of police for the city of
Antioch; DAVID O. LIVINGSTON,
individually and in his official capacity as
Sheriff for the County of Contra Costa; LREOY
D. BACA, individually and in his official
capacity as Sheriff for the County Los Angeles;
L. WALKER, individually and in his official
capacity as Clerk for the Los Angeles County
Superior Court; C. NEDAR, individually and in
his official capacity as Clerk for the Los
Angeles County Superior Court; LOS
ANGELES SUPERIOR COURT CLERK'S
OFFICE, in its official capacity; and DOES 130,

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Case No. C12-4693 JSC
STIPULATION AND [PROPOSED] ORDER
CONTINUING CASE MANAGEMENT
CONFERENCE and RELATED RULE 26
DISCLOSURES PENDING APPEARANCES OF
ALL NAMED DEFENDANTS, FILING OF THE
AMENDED COMPLAINT AND FILING OF
RESPONSIVE PLEADINGS THEREIN

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Defendants.
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This matter is currently scheduled for the Initial Case Management Conference on Thursday,

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April 18 and plaintiff is also required to file his amended complaint on that same date (see Order on

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Stipulation dated March 4, 2013 Docket No. 38). Plaintiff has attempted service on defendant David

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O. Livingston, Sheriff of Contra Costa County. Counsel from the Contra Costa County Counsel's
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STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE

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Office have made arrangements with plaintiff's counsel so that County Counsel for Contra Costa

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County may accept service for defendant Livingston of the amended complaint and said service of the

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amended complaint will take place sometime after the filing of the amended complaint on or before

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April 18, 2013.

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Given not all parties have yet formally appeared in the above captioned matter, and it may take

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another 30 - 45 days after April 18 for all appearances to be filed in the above captioned matter, the

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attorneys for the parties presently appearing agree it would be a more efficient use of Court resources

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and the time and costs for the parties that the Case Management Conference be continued again from

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Thursday April 18 to Thursday June 27 so that all named defendants who have been served and not

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dismissed may appear and participate in said CMC.

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Therefore the plaintiff and Antioch defendants and defendant Baca Stipulate and respectfully

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request that this Court continue the current date for the Initial Case Management Conference from

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Thursday, April 18 to Thursday, June 27, 2013 at 130 pm or to that future date most convenient for the

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Court.

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A joint CMC statement to be filed on or before Thursday June 20, 2013.

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The parties further agree that at the time of the Case Management Conference hearing, the date

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of Rule 26 (f) disclosures and ADR process should be re-scheduled to a new date mutually convenient

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to all parties and based on the results of the Case Management Conference all of which will help frame

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the issues.

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Based on this good cause the parties, acting by and through their respective legal counsel,

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stipulate and request

that the Court order the stipulation of the parties and that the initial Case

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Management Conference date be continued from April 18 to June 27, 2013. A joint Case Management

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Conference Statement to be filed Thursday June 20, 2013. The date for Rule 26 (f) disclosures; and the

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deadlines for filing the ADR Certification, Stipulation to ADR Process or Notice of Need for ADR Phone

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Conference, to be set by the Court at the initial Case Management Conference.

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STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE

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Dated: April 4, 2013.

Law Offices of Enrique Ramirez

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/s/

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By:
Enrique Ramirez

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Dated: April 4, 2013.

BERTRAND, FOX & ELLIOT

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/s/

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By:
Gregory M. Fox
Attorneys for Defendants
CITY OF ANTIOCH, LOREN BLEDSOE
and ALLAN CANTANDO

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Dated: April 4, 2013.

LOS ANGELES COUNTY COUNSEL

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/s/

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By:
Jonathan McCaverty,
Senior Deputy County Counsel
Attorney for Defendant Leroy D. Baca

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ATTORNEY ATTESTATION

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I hereby attest that I have on file all holograph signatures for any signatures indicated by a

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conformed signature (“/s/”) within this E-filed document.

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Dated: April 4, 2013

/s/
Gregory M. Fox

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ORDER

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Good cause appearing the Stipulation is So Ordered. The initial Case Management Conference
at 9:00 a.m.
date is continued from April 18 to June 27, 2013 or _______. A joint Case Management Conference

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Statement to be filed Thursday June 20, 2013 or ________. The date for Rule 26 (f) disclosures; and

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the deadlines for filing the ADR Certification, Stipulation to ADR Process or Notice of Need for ADR

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STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE

12 , 2013

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Dated: April

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Phone Conference, to be set by the Court at the initial Case Management Conference.

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STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE