THE PARTIES' STIPULATION AND ORDER TO EXTEND DEADLINE FOR COMPLETION OF DISCOVERY

WILLIAM H. ORRICK, District Judge.

Counsel for Defendants COUNTY OF DEL NORTE, RICHARD GIFFIN, CRECENT CITY; CRESCENT CITY POLICE DEPARTMENT, KEITH DOYLE, DOUG PLACK and JON ALEXANDER ("Defendants"), and Plaintiff MICHAEL RIESE ("Plaintiff") hereby stipulate to extend the deadline to complete discovery in this matter. The parties respectively request the Court to extend that deadline to June 10, 2014.

Good cause exists to grant this request for the reasons outlined in the parties previous Stipulation and request for the Court to continue the trial date and all related deadlines. Moreover, although that request was not granted, the Court did indicate a willingness to extend the discovery deadline to June 10, 2014.

ARGUMENT: See prior Stipulation for continuance of trial and all related deadlines. Since that time and the parties have agreed to the following deposition schedule:

There may be additional depositions required by the parties, including CHP Officer Mola, whose location has yet to be determined, and Jennifer Brown.

DISPOSITIVE MOTIONS

The parties also request a continuance to hear dispositive motions. The parties will need the certified transcripts of the witnesses to use in their dispositive motions. The turn around time for deposition transcripts is approximately two-weeks. Thus, the parties will not have the transcripts of Katie Micks and Sheriff Wilson, two key witnesses, until approximately June 24, 2014. The parties are requesting one week to prepare their dispositive motions with cites to the transcripts. Thus, the parties are requesting to file their dispositive motions on or before July 1, 2014, to be heard on or before Wednesday, August 6, 2014.

CONCLUSION

The parties hereby respectfully request an extension of the discovery cut-off deadline to June 10, 2014 and for dispositive motions to be heard on or before August 6, 2014. Good cause exists to grant this extension because (a) the parties have shown their good faith thus far in communicating via telephone and e-mail on a daily basis and a conference call on May 12, 2014 to schedule witness and party depositions, but are unable to schedule them before the current discovery cut-off date and (b) due to the nature of Plaintiff's allegations, there is a history of contacts with law enforcement officers that took place over a seven-year stretch. Due to the complexity of issues, the number of contacts to cover, and the number of parties with various interests in the case, witness depositions are taking the full seven hours, so parties have been unable to depose more than one party on a single date, despite trying to do so. The parties are working together and have made a significant amount of progress, but they need more time to complete witness depositions.

ORDER

PURSUANT TO STIPULATION AND THE COURT FINDING GOOD CAUSE, IT IS HEREBY ORDERED that: