STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL, PRE-TRIAL, LAW AND MOTION AND DISCOVERY DATES

WILLIAM B. SHUBB, District Judge.

STIPULATION

WHEREAS the parties, by and through their respective counsel have met and conferred and agreed;

WHEREAS discovery and dispositive motions were substantially delayed in order to permit sufficient time for Plaintiffs' counsel to file a motion to withdraw, for the Court to rule on the matter and for Plaintiffs and Plaintiffs' counsel to reconcile and be able to move forward with the case;

WHEREAS two litigation attorneys, including former counsel of record Ted Wood, have departed from the City of Stockton City Attorney's Office;

WHEREAS effective December 30, 2016, new counsel from Cota Cole LLP have associated into the case for Defendants;

WHEREAS due to the holiday period, obtaining fully executed substitutions of attorney from each individual defendant have been temporarily delayed;

WHEREAS Cota Cole LLP will be fully substituting into the case for the City Attorney as soon as the appropriate substitution documents are prepared and filed with the Court;

WHEREAS new counsel needs sufficient time to review and analyze the case, the current state of discovery, which is incomplete and prepare the case for the completion of discovery, potential dispositive motions and trial;

WHEREAS pre-trial and trial will need to be continued to accommodate continuing discovery and dispositive motions;

WHEREAS pending the Court's approval, the parties have agreed to continue all dates approximately 4-6 months depending upon the Court's schedule and ability to accommodate as follows:

SO STIPULATED

ORDER

The Court having considered the above stipulation of the parties and good cause appearing, hereby orders the following dates and deadlines be reset and continued as follows:

IT IS SO ORDERED.