JOINT STIPULATION TO ALTER/VACATE PRETRIAL SCHEDULING ORDER; [PROPOSED] ORDER

WILLIAM B. SHUBB, District Judge.

1. The parties, Plaintiff Timothy M. Callison and Defendants City of American Canyon, City of Vallejo, County of Napa and Officer Brett Schneider, by and through their designated counsel, pursuant to Local Rule 144(a) and Federal Rule of Civil Procedure 6, hereby submit their Joint Stipulation to Alter the Pretrial Scheduling Order in this matter.

2. Subject to the Court's approval, the parties propose the Court vacate the pretrial scheduling Order filed herein May 6, 2015 (Document 9) and schedule a new Pretrial Scheduling Conference 90 to 120 days out.

3. The proposed vacation of the current Order and scheduling of a new Pretrial Scheduling Conference is necessary and good cause exists for the requested stipulation. Plaintiff recently learned that the medical provider at the Napa County Correctional Facility is a third party vendor and will be filing a motion to amend his complaint to add California Forensic Medical Group (CFMG).

4. Concurrent with this Stipulation, counsel are filing their "Joint Stipulation for Leave to File First Amended Complaint; [Proposed] Order."

5. Adam Abel, Counsel for Defendants County of Napa, City of American Canyon and Officer Schneider, accepted a job to be an Assistant City Attorney for the City of Santa Rosa. Mr. Abel was substituted out on October 12, 2015, with Dale Allen being substituted in. Prior to Mr. Abel's substitution out, there was general agreement amongst counsel that the parties were unprepared to meet the deadlines set forth in the Pretrial Order of May 5, 2015. Depositions have not yet been scheduled and the parties are unprepared to make expert disclosures.

6. Counsel for Defendant City of Vallejo, Furah Faruqui, has accepted a position as an Assistant City Attorney for Redwood City, California and will be substituting out as counsel of record. Defendant City of Vallejo will be recruiting to an applicant to fill Ms Faruqui's position and this new counsel will undoubtedly need time to familiarize himself or herself with the file.

7. Plaintiff was incarcerated until late summer. Plaintiff is a veteran, receiving his medical care through the Veterans Administration. Scheduling appointments, particularly dental appointments, has delayed plaintiff's case.

8. Consequently, this is a civil rights matter, with a denial of medical care and personal injury components, it has numerous witnesses, including medical providers. Therefore, the parties respectfully submit they will require additional time to engage in extensive written discovery and numerous depositions. For this reason, the parties respectfully request this Court vacate the pretrial scheduling Order filed May 6, 2015, as requested, and schedule a new Pretrial Scheduling Conference 90 to 120 days out.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

PURSUANT TO STIPULATION, IT IS SO ORDERED:

The pretrial scheduling order filed May 6, 2015 is vacated.

A pretrial scheduling conferences is rescheduled for March 14,2016 at 1:30 p.m. A Joint Scheduling Conference Statement is due no later than February 29, 2016.