Moralez v. Circle A Foodmart and Gas et al

Filing 37

STIPULATION AND ORDER TO CONTINUE CMC re 36 STIPULATION WITH PROPOSED ORDER to Continue Case Management Conference filed by Francisca Moralez Initial Case Management Conference set for 1/17/2017 01:30 PM in Courtroom 4, 3rd Floor, Oakland. Signed by Magistrate Judge Kandis A. Westmore on 11/14/16. (sisS, COURT STAFF) (Filed on 11/14/2016)

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1 2 3 4 5 RUSSELL S. HUMPHREY, SBN 208744 343 E. Main Street, Suite 714 Stockton, Ca. 95202 Telephone: (209) 625-8976 Facsimile: (209) 625-8673 Email: russell@humphreylawgroup.net Attorney for Plaintiff FRANCISCA MORALEZ 6 7 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 12 13 FRANCISCA MORALEZ, 14 PLAINTIFF, 15 16 v. Case No. 4:15-cv-02759-KAW STIPULATION AND [PROPOSED] ORDER TO RESET CASE MANAGEMENT CONFERENCE TO SEPTEMBER 20, 2016 17 18 CIRCLE A FOODMART AND GAS, et al. 19 20 DEFENDANTS. 21 22 23 IT IS HEREBY STIPULATED AND REQUESTED by and between Plaintiff, FRANCISCA 24 MORALEZ, through her attorney of record Russell S. Humphrey ("Plaintiff"), and Defendant 25 CIRCLE A FOODMART AND GAS and GURNATH SINGH, through their attorney of record 26 Michael Welch, ("Defendant"), that the currently set Case Management Conference on November 27 28 14, 2016 be vacated and continued to January 17, 2017. Moralez v. Circel A, et al. Stipulation and Order 1 1 2 3 4 5 This stipulation is necessary because Plaintiff’s attorney Russell S. Humphrey has a scheduling conflict that cannot be reconciled on November 14, 2016. Attorney Russell S. Humphrey is currently in a jury trial in the San Joaquin County Superior Court before the Honorable Seth Hoyt. The charges are two counts of California Penal Code Section 187. 6 7 Dated: November 14, 2016 8 9 /s/ Russell S. Humphrey 10 By: RUSSELL S. HUMPRHEY Attorney for PLAINTIFF 11 12 13 14 /s/ Michael Welch ____________________________ By: MICHAEL WELCH Attorney for DEFENDANTS 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Moralez v. Circel A, et al. Stipulation and Order 2 1 2 3 4 5 RUSSELL S. HUMPHREY, SBN 208744 343 E. Main Street, Suite 714 Stockton, Ca. 95202 Telephone: (209) 625-8976 Facsimile: (209) 625-8673 Email: russell@humphreylawgroup.net Attorney for Plaintiff FRANCISCA MORALEZ 6 7 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 12 13 FRANCISCA MORALEZ, 14 PLAINTIFF, 15 v. 16 Case No. 4:15-cv-02759-KAW DECLARATION OF ATTORNEY RUSSELL S. HUMPHREY IN SUPPORT OF STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE 17 18 CIRCLE A FOODMART AND GAS, et al. 19 DEFENDANTS. 20 21 22 Declaration of Plaintiff’s Attorney Russell S. Humphrey in Support of Stipulation 23 24 1. I, Russell S. Humphrey, am an attorney duly licensed to practice law in the 25 highest state court in the state of California and the Northern District of California Federal 26 District Court. 27 28 2. I am the attorney of record for Plaintiff Francisca Moralez in the case of Moralez v. Circle A Foodmart and Gas, et al., case number 3:15-cv-2759. Moralez v. Circel A, et al. Stipulation and Order 1 1 3. 2 3 4 1:30 before the Honorable Kandis A. Westmore. 4. Joaquin County Superior Court. 6 8 9 10 11 I am unavailable to attend the Case Management Conference due to a conflict. I am currently in a jury trial before the Honorable Seth Hoyt in Department 21 of the San 5 7 There is a Case Management Conference currently set for November 15, 2016 at 5. The charges are two counts California Penal Code Section 187, Murder. 6. On Tuesday, November 15, 2016 I will be in jury selection. 7. I have met and conferred with co counsel and he is agreeable with the continuance. 12 13 14 Dated: November 14, 2016 /s/ Russell S. Humphrey Attorney for Plaintiff 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Moralez v. Circel A, et al. Stipulation and Order 2 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 12 FRANCISCA MORALEZ, Case No.: 3:15-cv-02759-KAW Plaintiff, 13 [PROPOSED] ORDER 14 vs. 15 CIRCLE A FOODMART AND GAS, et al., 16 17 Defendants. 18 19 20 Good cause being found, the court orders the currently set Case Management 21 Conference be vacated and continued to January 17, 2017 at 1:30 p.m. in Courtroom 4 before 22 the Honorable Kandis A. Westmore. 23 24 25 IT IS SO ORDERED. 26 27 28 [PROPOSED] ORDER 1 2 11/14/16 DATED: _______________ ____________________________ HONORABLE KANDIS A. WESTMORE MAGISTRATE JUDGE 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [PROPOSED] ORDER

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