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1 Robert D.

Rodriguez SBN: 242396


Robert D. Rodriguez, Attorney at Law
2 429 13th Street
Modesto, California 95354
3 (209) 596-4263 (telephone)

4 Attorney for plaintiffs,


NOHEMI ORIGEL and WILMER D. ORIGEL
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8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF STANISLAUS
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10 NOHEMI ORIGEL, WILMER D. ORIGEL, CASE NUMBER: 657996

11 Plaintiffs, STIPULATION TO VACATE AND


CONTINUE SETTLEMENT
12 vs. CONFERENCE AND JURY TRIAL
DATES AND SET FOR FURTHER
13 CASE MANAGEMENT
14 LUIS DIAZ, FRANK DICKSON, SAMUEL CONFERENCE DATE
MARTINEZ, TEAMSTERS LOCAL UNION NO.
15 Judge: Hon. Timothy Salter
948; and DOES 1 through 50, inclusive,
Date Action Filed: September 14, 2010
16 Settlement Conference Date:
Defendants.
August 8, 2011
17 Trial Date: August 23, 2011
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IT IS HEREBY STIPULATED between plaintiff Nohemi Origel and Wilmer D. Origel,
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by and through their attorney of record Robert D. Rodriguez and defendants Luis Diaz, Frank
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Dickson, Samuel Martinez, Teamsters Local Union No. 948 by and through their attorney of
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23 record Kenneth C. Absalom that the settlement conference of August 8, 2011 at 8:30 a.m. in

24 department 22 and the jury trial of August 23, 2011 at 9:30 a.m. in department 22, is hereby

25 vacated.
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______________________________________________________________________________
STIPULATION AND ORDER

Case No. 657996


1 The reason for the stipulation is that depositions of a witness for plaintiffs could not be
2 taken until May 3, 2011, and plaintiffs will not be able to file a Motion for Summary Judgment in
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a timely manner. No prejudice will exist to either party.
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It is respectfully requested that the settlement conference and jury trial dates be vacated
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and this be assigned a new case management conference date.
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7 IT IS STIPULATED that any and all discovery will be conducted pursuant to the new trial

8 date.

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10 Date: April , 2011 __________________________________________
11 James Achermann for Kenneth C. Absalom
Attorneys for defendants LUIS DIAZ, FRANK
12 DICKSON, SAMUEL MARTINEZ, TEAMSTERS
LOCAL UNION NO. 948
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Date: April , 2011 __________________________________________
16 Robert D. Rodriguez
Attorney for plaintiffs NOHEMI ORIGEL and
17 WILMER D. ORIGEL
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ORDER
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After reading the above stipulation, IT IS HEREBY ORDERED, ADJUDGED, AND
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DECREED that the settlement conference date of August 8, 2011 at 8:30 a.m. in department 22
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and the jury trial of August 23, 2011 at 9:30 a.m. in department 22 is hereby vacated.
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23 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that there shall be a new

24 case management conference sate of ____________________________________________.


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Date: _____________________________________
27 Judge of the Superior Court

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______________________________________________________________________________
STIPULATION AND ORDER

Case No. 657996


1 Stanislaus County Case No.: 657996
2 Case Title: ORIGEL ET AL. v. DIAZ ET AL.
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SUPERIOR COURT OF CALIFORNIA, COUNTY OF STANISLAUS
4 PROOF OF SERVICE

5 I am a resident of the United States and the State of California. I am employed in the
County of Stanislaus. My business address is 429 13th Modesto, CA. 95354. My telephone is
6 (209) 596-4263. I am over the age of eighteen years. I am not a party to the action or
7 proceeding.

8 I am familiar with the practice for the collection and processing of correspondence for
mailing with the United States Postal Service for the Law Office of Robert D. Rodriguez. In
9 accordance with the ordinary course of business, the below mentioned document(s) would have
been deposited with the United States Postal Service on the same day on which it was placed for
10 deposit:
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On April , 2011, I served the following documents(s):
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13 1. STIPULATION TO VACATE AND CONTINUE SETTLEMENT
CONFERENCE AND JURY TRIAL DATES AND SET FOR FURTHER CASE
14 MANAGEMENT CONFERENCE DATE

15 XXX_ by placing, or causing to be placed, a true copy thereof enclosed in a sealed envelope with
postage thereon fully prepaid, in the United States mail at Modesto, CA, addresses as set forth
16 below.
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_____ by personally delivering or causing to be delivered a true copy thereof to the person(s) at
18 the address (es) set forth.

19 _____ by causing a true copy thereof to be transmitted via facsimile followed by first class mail
pursuant to the California Rules of Court.
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21 Luis Diaz, Samuel Martinez, Frank Dickson, TEAMSTERS LOCAL UNION NO. 948 c/o
Kenneth Absalom, Esq.
22 Nevin & Absalom
22 Battery St #333
23 San Francisco, CA 94111
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I declare under penalty of perjury under the laws of the State of California that the
25 foregoing is true and correct and that this document was executed this day of April 2011, in
Modesto, CA.
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__________________________________
27 Robert D. Rodriguez
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______________________________________________________________________________
STIPULATION AND ORDER

Case No. 657996

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