Filed: Jun. 10, 2015
Latest Update: Jun. 10, 2015
Summary: STIPULATED REQUEST TO MODIFY SCHEDULING ORDER; ORDER THEREON MORRISON C. ENGLAND, Jr. , Chief District Judge . IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ROBERT BARRON, and Defendants CITY OF REDDING, BRANDON LARGENT, and CHIEF ROBERT F. PAOLETTI, (collectively, the "Parties"), by and through their undersigned Counsel, pursuant to Local Rules 143 and 144 as follows: 1. The Parties respectfully request the District Court modify the Scheduling Conference Order to allow appro
Summary: STIPULATED REQUEST TO MODIFY SCHEDULING ORDER; ORDER THEREON MORRISON C. ENGLAND, Jr. , Chief District Judge . IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ROBERT BARRON, and Defendants CITY OF REDDING, BRANDON LARGENT, and CHIEF ROBERT F. PAOLETTI, (collectively, the "Parties"), by and through their undersigned Counsel, pursuant to Local Rules 143 and 144 as follows: 1. The Parties respectfully request the District Court modify the Scheduling Conference Order to allow approx..
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STIPULATED REQUEST TO MODIFY SCHEDULING ORDER; ORDER THEREON
MORRISON C. ENGLAND, Jr., Chief District Judge.
IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ROBERT BARRON, and Defendants CITY OF REDDING, BRANDON LARGENT, and CHIEF ROBERT F. PAOLETTI, (collectively, the "Parties"), by and through their undersigned Counsel, pursuant to Local Rules 143 and 144 as follows:
1. The Parties respectfully request the District Court modify the Scheduling Conference Order to allow approximately 40 additional days to complete non-expert discovery based on good cause appearing therefore as more fully set forth below. The Final Pretrial and Trial dates would remain the same.
2. On November 19, 2014 the Court issued its Initial Scheduling Order setting certain dates and deadlines, including discovery cut-offs, dispositive motion hearing deadlines and trial. Dckt. No. 10.
3. The Parties seek modification of the dates currently set for the close of non-expert discovery.
4. The Parties submit good cause exists to modify the current scheduling order due to counsels' respective schedules, and the remaining voluminous discovery that must be completed. The Parties have met and conferred regarding the discovery issues and deposition scheduling, and have agreed that approximately 40 additional days will be necessary to resolve the pending discovery issues and complete non-expert and expert discovery.
5. The Parties submit that the movement of dates will allow counsel to properly complete non-expert discovery. The Parties submit that the proposed modified dates will not affect the Pretrial Scheduling Conference or trial date.
8. Therefore, the Parties respectfully submit that good cause exists to amend the Pretrial Scheduling Order dated November 19, 2014, and hereby propose the following schedule for further proceedings:
Current Date Proposed Date
Expert Disclosure: September 2, 2015 Unchanged
Non-Expert Discovery Cutoff: July 2, 2015 August 14, 2015
Supplemental Expert Disclosure: September 22, 2015 Unchanged
Expert Discovery Cutoff: November 13, 2015 Unchanged
Pretrial Motion Filing Deadline: November 13, 2015 Unchanged
Pretrial Motion Hearing Deadline: January 7, 2016 Unchanged
Final Pretrial Conference: March 17, 2016 Unchanged
Trial: May 2, 2016 Unchanged
IT IS SO STIPULATED, BY AND THROUGH COUNSEL OF RECORD.
Dated: June 3, 2015. LAW OFFICES OF DALE K. GALIPO
By: /s/Dale K. Galipo
Dale K. Galipo, Esq.
Dated: June 3, 2015. LAW OFFICES OF VICKI I. SARMIENTO
By: /s/Vicki I. Sarmiento
Vicki I. Sarmiento, Esq.
Dated: June 3, 2015. BRICKWOOD LAW OFFICE
By: /s/Gary Brickwood
Gary Brickwood, Esq.
Dated: June 3, 2015. GOYETTE & ASSOCIATES, INC.
A Professional Law Corporation
By: /s/Sean D. O'Dowd
Sean D. O'Dowd, Esq.
ORDER
Having reviewed the above stipulation and good cause appearing therefore, IT IS HEREBY ORDERED that the Scheduling Conference Order be modified as follows:
Expert Disclosure: September 2, 2015 (Unchanged)
Non-Expert Discovery Cutoff: August 14, 2015
Supplemental Expert Disclosure: September 22, 2015 (Unchanged)
Expert Discovery Cutoff: November 13, 2015 (Unchanged)
Pretrial Motion Filing Deadline: November 13, 2015 (Unchanged)
Pretrial Motion Hearing Deadline: January 7, 2016 (Unchanged)
The Pretrial Conference date of March 17, 2016 at 2:00 p.m. in Courtroom 7, before the Honorable Morrison C. England, Jr., and trial date of May 2, 2016 at 9:00 a.m. in Courtroom 7, before the Honorable Morrison C. England, Jr., remain unchanged.
IT IS SO ORDERED.
