Filed: May 05, 2017
Latest Update: May 05, 2017
Summary: STIPULATION AND ORDER CONTINUING FACT DISCOVERY DEADLINES TROY L. NUNLEY , District Judge . Plaintiff, CYNTHIA DE JESUS-EDMUNSON, and Defendant, CITY OF SACRAMENTO, by and through their respective attorneys, Anthony E. Goldsmith, Steven L. Derby, and Katherine E. Underwood, hereby jointly stipulate and respectfully request the trial date and pretrial deadlines in this case to be continued for good cause as shown below. Presently, trial in this case is scheduled to begin on June 4, 2018. Thi
Summary: STIPULATION AND ORDER CONTINUING FACT DISCOVERY DEADLINES TROY L. NUNLEY , District Judge . Plaintiff, CYNTHIA DE JESUS-EDMUNSON, and Defendant, CITY OF SACRAMENTO, by and through their respective attorneys, Anthony E. Goldsmith, Steven L. Derby, and Katherine E. Underwood, hereby jointly stipulate and respectfully request the trial date and pretrial deadlines in this case to be continued for good cause as shown below. Presently, trial in this case is scheduled to begin on June 4, 2018. This..
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STIPULATION AND ORDER CONTINUING FACT DISCOVERY DEADLINES
TROY L. NUNLEY, District Judge.
Plaintiff, CYNTHIA DE JESUS-EDMUNSON, and Defendant, CITY OF SACRAMENTO, by and through their respective attorneys, Anthony E. Goldsmith, Steven L. Derby, and Katherine E. Underwood, hereby jointly stipulate and respectfully request the trial date and pretrial deadlines in this case to be continued for good cause as shown below. Presently, trial in this case is scheduled to begin on June 4, 2018. This request for an extension of discovery deadlines is based on the following good cause:
1. On March 11, 2015, Plaintiff, by and through counsel, filed her Complaint for damages and injunctive relief, arising out of an incident that occurred on or about February 20, 2014, which involves the alleged deprivation of Plaintiff's civil rights, as well as personal injuries.
2. Plaintiff has endured two serious illnesses unrelated to her injuries allegedly sustained in the case before the Court. Additionally, Plaintiff is in the process of recovering additional medical records related to this case and both parties want to be sure that Defendants have all of Plaintiff's medical records before taking her deposition. Accordingly, the parties ask that the Court to extend the discovery cut-off date in this case from July 14, 2017 to September 14, 2017.
3. This request for an extension of discovery deadlines will not impact the trial date or any other discovery and motion dates in the case and although the parties understand the importance of keeping the Court's timeline, all involved are working together cooperatively and believe the extension will likely result in further settlement discussions, as opposed to having to proceed to trial.
4. Based on the foregoing, the parties jointly stipulate and request that the Court continue the current discovery cut-off date from July 14, 2017 to September 14, 2017.
IT IS SO STPULATED.
THE STIPULATION OF THE PARTIES IS APPROVED AND IT IS SO ORDERED.
