STIPULATION RE: SUMMARY JUDGMENT HEARING; PRETRIAL CONFERENCE; and TRIAL; [PROPOSED] ORDER

WILLIAM B. SHUBB, District Judge.

TO THE CLERK OF THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

Plaintiff JOANNE BLIGHT ("Plaintiff") and Defendants CITY OF MANTECA, ARMANDO GARCIA, IAN OSBORN, CHRIS MRAZ, and PAUL CARMONA ("Defendants") hereby respectfully request continuation of the summary judgment hearing in this Case, as well as the Pretrial Conference date and Trial date.

Summary judgment is currently scheduled for August 7, 2017. The Pretrial Conference is set for August 28th, with trial on October 17, 2017. The parties have diligently litigated this case, but the requested scheduling changes are required in order to permit adequate time in between the hearing on the pending summary judgment motion, and the pretrial conference and trial.

Good cause exists for this stipulation. On July 17, 2017, Plaintiff's counsel became aware of an immovable scheduling conflict with the summary judgment hearing. Counsel repeatedly attempted to resolve the conflict, to no avail. The parties met-and-conferred and both sides are available on the Court's next available motion hearing date (August 21, 2017).

Because an August 21st hearing date would only leave one week until the Pretrial Conference, and 8 weeks until the trial, the parties met-and-conferred and believe it best to also move the Pretrial Conference and trial dates. Moving all three dates provides the Court time to consider and rule upon the moving and opposing papers that will be filed in connection with the summary judgment motion, which involves an extensive volume of evidence, and gives the parties adequate time between any ruling and trial, including the time needed for preparation and submission of trial documents. A short trial continuance also resolves a conflict that recently arose on Defendants' counsel's calendar. A matter that was supposed to settle is now certain to go to trial. That matter is set for October 10, 2017 in San Joaquin County, and anticipated to go two weeks.

Based on the foregoing circumstances, by and through their respective counsel of record, the parties hereby stipulate and respectfully request the following:

1. That the hearing date for Defendants' summary judgment motion be continued from August 7, 2017 to August 21, 2017;

2. That the Pretrial Conference be continued from August 28, 2017 to October 10, 2017;1 and,

3. That the trial date be continued from October 17, 2017 to December 12, 2017.

PURSUANT TO THE FOREGOING STIPULATION, IT HEREBY ORDERED:

1. That the hearing date for Defendants' summary judgment motion is continued from August 7, 2017 to September 18, 2017 at 1:30 p.m.;

2. That the Pretrial Conference is continued from August 28, 2017 to November 20, 2017 at 1:30 p.m., and

3. That the trial date is continued from October 17, 2017 to January 17, 2018 at 9:00 a.m.