JOINT STIPULATION TO MODIFY PRE-TRIAL SCHEDULING ORDER AND ORDER

KIMBERLY J. MUELLER, District Judge.

This Stipulation is entered into by and between Plaintiff GERALD FRIENDS ("Plaintiff") and Defendants SAN JOAQUIN COUNTY, SAN JOAQUIN COUNTY SHERIFF DEPARTMENT, SAN JOAQUIN COUNTY SHERIFF STEVE MOORE, SHERIFF DEPUTY SGT. ORAM, SHERIFF DEPUTY PABLO MARMOLEJO, SHERIFF DEPUTY RUBEN RODRIGUEZ, SHERIFF DEPUTY AARON (PYLE) SAVAGE, SHERIFF DEPUTY ROBERT L. WAGNER, SHERIFF DEPUTY TYLER GILLIS, and SHERIFF DEPUTY KATRINA AGUILAR ("Defendants") (collectively, "The Parties") by and through their respective counsel. The Parties enter into this stipulation and proposed order in compliance with the Federal Rule of Civil Procedure 16(b) and the requirements of the scheduling order. The parties request to briefly continue non-expert and expert discovery deadlines as well as the dispositive motion hearing deadline by one month.

WHEREAS, this case does not currently have a trial date;

WHEREAS, on November 2, 2018, the Court extended the discovery deadlines and dispositive motion deadlines by one month;

WHEREAS, the Parties have diligently been participating in non-expert discovery, including completing the exchange of several sets of written discovery, the deposition of Plaintiff and the depositions of all San Joaquin County officers involved in the incident that led to the filing of this suit;

WHEREAS, the Parties intend to complete four (4) or (5) depositions of third-party witnesses and complete a limited amount of additional written discovery and third-party subpoenas;

WHEREAS, the Parties conducted a settlement conference before Magistrate Judge Allison Claire on February 7, 2019. The Parties were unable to reach a resolution. The Parties believe further settlement discussions in the next 30 days may be fruitful to resolve the matter. However, engaging in further non-expert discovery, designating experts, and preparing for expert discovery will increase the costs for both sides and will make settlement more difficult to achieve.

WHEREAS, the Parties have conferred and propose the following scheduling amendments:

Good cause exists for a brief 30-day continuance of the above deadlines to allow the parties to continue to engage in settlement negotiations without incurring additional fees. Thus, the parties are requesting a 30 day continuance to potentially resolve this matter.

IT IS SO STIPULATED.

ORDER

The scheduling order is modified as follows:

IT IS SO ORDERED.