Alvarez v. Sonoma County et al
Filing
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STIPULATION AND ORDER re 46 Stipulated Request to Continue Early Neutral Evaluation and [Proposed] Order filed by S. Sullivan, Julie S. Paik, Javier Agusto Alvarez, Sr., Anna New, Laurie B. Lapidus, Sonoma County. Signed by Judge Edward M. Chen on 7/23/13. (bpf, COURT STAFF) (Filed on 7/23/2013)
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Thomas F. Bertrand, State Bar No. 056560
Richard W. Osman, State Bar No. 167993
Sheila D. Crawford, State Bar No. 298272
BERTRAND, FOX & ELLIOT
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: (415) 353-0999
Facsimile: (415) 353-0990
Email: rosman@bfesf.com
Attorneys for Defendants
COUNTY OF SONOMA, JULIE S. PAIK,
S. SULLIVAN, LAURIE LAPIDUS and ANNA NEW
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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Case No. C 12-5606 (EMC)
JAVIER AGUSTO ALVAREZ,
Plaintiff,
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STIPULATED REQUEST TO CONTINUE
EARLY NEUTRAL EVALUATION AND
[PROPOSED] ORDER
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v.
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SONOMA COUNTY, JULIE S. PAIK, LISA
M. CERVANTES, ANNA NEW, JAN C.
STURLA, MEGAN F. ALVAREZ,
EXCHANGE BANK and DOES 1 through 50,
INCLUSIVE,
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Hon. Edward M. Chen
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Defendants.
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STIPULATION
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The parties, Plaintiff JAVIER ALVAREZ and Defendants COUNTY OF SONOMA, JULIE S.
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PAIK, S. SULLIVAN, LAURIE LAPIDUS and ANNA NEW (hereinafter “Sonoma Defendants”), by
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and through their attorney of record, hereby stipulate as follows:
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1.
On May 16, 2013, the Court referred this matter to Early Neutral Evaluation (ENE) within
90 days. (Docket No. 35.)
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STIPULATED REQUEST TO CONTINUE EARLY NEUTRAL EVALUATION AND [PROPOSED] ORDER
Alvarez v. Sonoma County, et al.
U.S.D.C. Northern District of CA Case No. C 12-5606 (EMC)
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2.
On June 4, 2013, the Court assigned Marjorie Gelb as the Evaluator for this case. (Docket
No. 40.) The ENE was scheduled for August 1, 2013.
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On June 28, 2013, Plaintiff ALVAREZ filed a second amended complaint containing new
allegations and naming additional defendants. (Docket No. 41.)
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On July 12, 2013, Sonoma Defendants filed a motion to dismiss Plaintiff’s second
amended complaint. (Docket No. 45.)
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On July 17, 2013, Richard Osman, counsel for Sonoma Defendants, contacted Plaintiff
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ALVAREZ to meet and confer regarding continuing the ENE for 60 days in order to accommodate the
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pending motion to dismiss. Plaintiff ALVAREZ agreed to extend the ENE for 60 days.
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6.
On July 18, 2013, Sheila Crawford, counsel for Sonoma Defendants, contacted the
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Evaluator, Marjorie Gelb, to discuss continuing the ENE. Given the current status of this matter, Ms.
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Gelb agreed continuing the ENE for 60 days was reasonable.
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7.
The Parties respectfully request that the Court approve this stipulation and continue the
ENE for 60 days from August 14, 2013.
IT IS SO STIPULATED.
Dated: July 22, 2013
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BERTRAND, FOX & ELLIOT
By:
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/s/ Sheila D. Crawford
Sheila D. Crawford
Richard W. Osman
Attorneys for Defendants
COUNTY OF SONOMA, JULIE S. PAIK,
S. SULLIVAN. LAURIE LAPIDUS and ANNA
NEW
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Dated: July 22, 2013
Plaintiff, In Pro Per
By:
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/s/ Javier Alvarez
Javier Alvarez
Plaintiff
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STIPULATED REQUEST TO CONTINUE EARLY NEUTRAL EVALUATION AND [PROPOSED] ORDER
Alvarez v. Sonoma County, et al.
U.S.D.C. Northern District of CA Case No. C 12-5606 (EMC)
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Early Neutral Evaluation of this matter be continued for 60 days from August 14, 2013.
7/23
en
d M. Ch
dwar
Judge E
ER
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UNITED STATES DISTRICT COURT JUDGE
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ERED
O ORD
Hon. Edward M. Chen
IT IS S
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, 2013
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FO
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DATED:
UNIT
ED
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S DISTRICT
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C
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R NIA
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IT IS SO ORDERED.
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Having reviewed the stipulation between the parties herein, IT IS HEREBY ORDERED that the
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[PROPOSED] ORDER
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D IS T IC T O
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C
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STIPULATED REQUEST TO CONTINUE EARLY NEUTRAL EVALUATION AND [PROPOSED] ORDER
Alvarez v. Sonoma County, et al.
U.S.D.C. Northern District of CA Case No. C 12-5606 (EMC)
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CERTIFICATE OF SERVICE
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I, the undersigned, declare that I am employed in the County of San Francisco, California; I am
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over the age of eighteen years and not a party to the within cause; and my business address is 2749 Hyde
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Street, San Francisco, California 94109.
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I am readily familiar with the practice of Bertrand, Fox, & Elliot with respect to the collection and
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processing of pleadings, discovery documents, motions and all other documents which must be served
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upon opposing parties or other counsel in litigation. On the same day that correspondence is placed for
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collection and mailing, it is deposited in the ordinary course of business with the United States Postal
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Service in a sealed envelope with postage fully prepaid.
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On July 22, 2013, I served the following documents,
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STIPULATED REQUEST TO CONTINUE EARLY NEUTRAL EVALUATION
AND [PROPOSED] ORDER
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on the following interested parties:
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Javier A. Alverez
1014 Hopper Avenue #402
Santa Rosa, California 95403
Tel: (415) 827-6322
Email: Javdog396@gmail.com
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Pro Se Plaintiff
Said service was performed in the following manner:
()
BY U.S. POSTAL SERVICE (Mail): I placed each such document in a sealed envelope
addressed at noted above, with first-class mail postage thereon fully prepaid, for collection and
mailing at San Francisco, California, following the above-stated business practice, on this date.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed July 22, 2013, at San Francisco, California.
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/s/ John O'Rourke
John O'Rourke
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CERTIFICATE OF SERVICE
Alvarez v. Sonoma County, et al.
U.S.D.C. Northern District of CA Case No. C 12-5606 EMC
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