STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER AND EXTEND THE TIME TO RESPOND TO THIRD AMENDED COMPLAINT

[FRCP 16; L.R. 143 and 144]

WILLIAM B. SHUBB, District Judge.

COMES NOW Plaintiffs Aleshna Kumari, A.K., A.S., and A.K.M. (herein "Plaintiffs") and Defendants County of Sacramento, Jesse Gomez-Coates (erroneously named herein as Jesse Gomez-Coats), Janelle Gonzales (erroneously named herein as Janelle Gonzalez), and Leona Williams (herein "County Defendants"), by and through their respective counsel and subject to the approval of this Court, hereby stipulate and respectfully request that this Court's Pretrial Scheduling Order dated May 8, 2018 [ECF No. 5], be modified to reflect new deadlines and cut-off dates as follows, or as to accommodate the Court's docket, in order for the parties to participate in private mediation:

WHEREAS, Plaintiffs filed their Third Amended Complaint for violations of civil and constitutional rights in the Eastern District of California on December 10, 2018;

WHEREAS, the parties submitted a Stipulation to Extend Time to Respond to the Third Amended Complaint to permit Plaintiffs time to determine whether to seek leave to amend their complaint to assert claims against additional defendants, specifically the Foster Family Home and Small Family Home Insurance Fund and/or individuals or entities associated therewith. This Court granted the parties' request and ordered that the County Defendants' response to the Third Amended Complaint is due on or before February 7, 2019 [ECF No. 24];

WHEREAS, counsel for all parties have met and discussed the posture of this case, and agree that it would be beneficial to participate in private mediation at this time;

WHEREAS, should this matter not settle at mediation, Plaintiffs still anticipate seeking leave to amend their complaint to assert claims against said additional defendants;

WHEREAS, the parties agree that County Defendants shall have an extension of eighty-five (85) days to respond to the Third Amended Complaint to provide the parties with sufficient time to participate in mediation and to provide Plaintiffs additional time to file a motion for leave to amend to assert claims against additional defendants should this matter not settle;

WHEREAS, pursuant to this stipulation of the parties, County Defendants' response to the Third Amended Complaint is due on or before May 3, 2019;

WHEREAS, counsel for all parties have met and conferred and agree that it would be in the interests of justice and judicial economy and that good causes exists for the modification of the scheduling order;

WHEREAS, this stipulation is not being made for the purpose of delay, or any other improper purpose;

WHEREAS, continuing the trial date and pretrial deadlines will not prejudice any party or their counsel;

WHEREAS, this is the parties' first request to modify the scheduling order.

IT IS SO STIPULATED.

IT IS SO ORDERED. The dates are modified as follows: