Figueroa, et al. v. City of Fresno

Filing 22

STIPULATION and ORDER 20 for extension of time signed by Chief Judge Morrison C. England, Jr. on 2/10/2016. Non-Expert Discovery cut-off date shall be 4/18/2016. Expert Disclosure now due on 6/20/2016. Hearing date for Dispositive Motions shall be 10/13/2016. (Marciel, M)

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ARTURO J. GONZALEZ (CA SBN 121490)
[e-mail]
ALEXANDRIA A. AMEZCUA (CA SBN
247507)
[e-mail]
STUART C. PLUNKETT (CA SBN 187971)
[e-mail]
MOLLY A. SMOLEN (CA SBN 293328)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522

UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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Attorneys for Defendants

Attorneys for Plaintiffs

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BRUCE D. PRAET (CA SBN 119430)
[e-mail]
FERGUSON, PRAET & SHERMAN
1631 East 18th Street
Santa Ana, California 92705-7101
Telephone: [phone]
Fax: [phone]

AURORA FIGUEROA, on her own behalf, and as
successor in interest to MARTIN FIGUEROA,
and LIZETTE FIGUEROA, on her own behalf,
Plaintiffs,
v.
CITY OF FRESNO, a municipal corporation, and
DOES 1 through 50, inclusive,
Defendants.

Case No.

1:15-cv-00349-MCE-BAM

STIPULATION AND ORDER
EXTENDING SCHEDULE

Trial Date: March 20, 2017

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Pursuant to Civil Local Rule 144, Plaintiffs Aurora Figueroa and Lizette Figueroa, and

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Defendant City of Fresno (collectively, “the parties”) by and through their respective counsel,

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stipulate to the following request to extend the case schedule to permit additional time to conduct

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discovery:

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WHEREAS, pursuant to the Scheduling Order, the non-expert discovery cutoff is March
18, 2016;

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WHEREAS, pursuant to the Scheduling Order, the expert disclosure cutoff is May 20,
2016;
WHEREAS, pursuant to the Scheduling Order, the last day to hear dispositive motions is
September 15, 2016;
WHEREAS, two key witnesses are unavailable for deposition during the fact discovery
period due to medical issues;
WHEREAS, pursuant to Civil Local Rule 144, the parties may file a stipulation requesting
an order extending time to the case schedule;

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WHEREAS, the parties are not seeking any modification of other deadlines;

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NOW THEREFORE, the Parties hereby stipulate and request that

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Time for non-expert discovery cutoff be moved to April 18, 2016;

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Time for expert disclosure cutoff be moved to June 20, 2016; and

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Time for dispositive motion hearing be moved to October 13, 2016.

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IT IS SO STIPULATED.

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Dated: February 8, 2016

MORRISON & FOERSTER LLP

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By: /s/ Alexandria A. Amezcua
ALEXANDRIA A. AMEZCUA

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Attorneys for Plaintiffs

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FERGUSON, PRAET & SHERMAN

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By: /s/ Bruce D. Praet (as authorized on 02/05/16)
BRUCE D. PRAET

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Attorneys for Defendants

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ORDER
Pursuant to the foregoing stipulation, the non-expert discovery cut-off date shall be April

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18, 2016. The expert disclosure cut-off date shall be June 20, 2016. The hearing date for

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dispositive motions shall be October 13, 2016.

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IT IS SO ORDERED.
Dated: February 10, 2016

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