JOINT STIPULATION TO RESCHEDULE HEARING DATE ON ALL MOTIONS FOR SUMMARY JUDGMENT AND COUNTY DEFENDANTS' MOTION TO EXCLUDE PLAINTIFF'S EXPERTS, AND OTHER RELIEF; [PROPOSED] ORDER

RICHARD SEEBORG, District Judge.

This Joint Stipulation is submitted by all parties in this action, through their respective counsel, including: Plaintiff James Neuroth ("Plaintiff"); Defendants the County of Mendocino, Mendocino County Sheriff Thomas Allman, Sheriff's Captain Timothy Pearce, and current/former Sheriff's Deputies Lorrie Knapp, Frank Masterson, Craig Bernardi, Michael Grant, Jeanette Holum, Robert Page, and Christine De Los Santos (collectively, "County Defendants"); California Forensic Medical Group, Inc. and Jennifer Caudillo (collectively, "CFMG Defendants"); Correctional Medical Group Companies, Inc., Dr. Taylor Fithian, Elaine Hustedt, and Claire Teske (collectively, "CMGC Defendants"); and the City of Willits, former Willits Police Chief Gerardo Gonzalez, and current/former Willits Police Officers Kevin Leef and Jeff Andrade (collectively, "Willits Defendants"). Through this Stipulation, the parties request the Court to reschedule the hearings on all Defendants' Motions for Summary Judgment, as well as County Defendants' Motion to Exclude Reports and Testimony and Plaintiff's Experts Michael Baden, Michael Freeman, Richard Hayward, and John Ryan (the "Expert Exclusion Motion"), from August 2, 2018, to August 9, 2018, as well as provide Plaintiff with additional time to respond to the Expert Exclusion Motion. The parties believe that good cause supports their request, as set forth below.

RECITALS

A. In its Order Extending Dispositive Motion Deadlines entered on March 30, 3018 (Dkt. No. 249), the Court set the hearing date on the parties' dispositive motions for August 2, 2018.

B. On May 25, 2018, Defendants filed the following separate Motions for Summary Judgment, all of which are currently set to be heard on August 2, 2018, at 1:30 p.m.:

B. On June 28-29, 2018, County Defendants filed a Motion to Exclude Reports and Testimony of Plaintiff's Experts Michael Baden, Michael Freeman, Richard Hayward, and John Ryan (the "Expert Exclusion Motion", filed as Dkt. Nos. 297-300). County Defendants noticed the hearing on that motion to be held on August 2, 2018, at the same time as the hearings on all Defendants' Motions for Summary Judgment.

C. The parties agree to provide Plaintiff with additional time to respond to the Expert Exclusion Motion through and including July 19, 2018, and to move the hearing on that motion as well as all the Motions for Summary judgment to August 9, 2018, at 1:30 p.m. This will enable all pending motions to be heard at the same time. According to the Court's website, this is an available hearing date for the Court.

AGREEMENT

1. The parties request the Court to reschedule the hearings on all Motions for Summary Judgment (Dkt. Nos. 261, 262, 263, 265, and 281) and County Defendants' Expert Exclusion Motion (Dkt. No. 300) from August 2, 2018, to August 9, 2018, at 1:30 p.m.

2. The parties request the Court to provide Plaintiff through and including July 19, 2018, to file an opposition to County Defendants' Expert Exclusion Motion.

3. Nothing in this Stipulation and request for order is intended to modify the other matters addressed in any Court order unless expressly identified herein, nor does it preclude the parties from seeking additional relief from this Court.

IT IS SO STIPULATED.

ORDER

The parties' foregoing stipulation is approved, and with good cause appearing therefor,

IT IS HEREBY ORDERED that the previous Order Extending Dispositive Motion Deadlines entered on March 30, 2018 (Dkt. No. 249) is modified, and the following dates are set in the instant case:

2. Plaintiff shall have through and including July 19, 2018, to file an opposition to County Defendants' Expert Exclusion Motion.

IT IS SO ORDERED.