Johnson v. City of Ridgecrest

Filing 27

ORDER GRANTING 26 Stipulation to Continue Discovery Deadline for the Sole Purpose of Taking One Additional Deposition, signed by Magistrate Judge Jennifer L. Thurston on 12/2/2016. (Hall, S)

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W. KEITH LEMIEUX (SBN 161850)
MICHAEL SILANDER (SBN 202609)
LEMIEUX & O'NEILL
4165 E. Thousand Oaks Blvd., Suite 350
Westlake Village, California 91362
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant CITY OF RIDGECREST
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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WILLIAM JOHNSON,
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Plaintiff,
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Vs.
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CITY OF RIDGECREST, a California
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Municipality, and DOES 1 through 20, inclusive, )
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Defendants.
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CASE NO.: 1:15-CV-01540 JLT
STIPULATION TO CONTINUE DISCOVERY
DEADLINE FOR THE SOLE PURPOSE OF
TAKING ONE ADDITIONAL DEPOSITION;
[PROPOSED] ORDER
(Doc. 26)

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TO THIS HONORABLE COURT:

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Defendant CITY OF RIDGECREST (“City”) and Plaintiff WILLIAM JOHNSON (“Plaintiff”)

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stipulate as follows:
The current discovery deadline is December 12, 2016. Plaintiff’s deposition is currently

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scheduled for December 7, 2016.
However, counsel for City and Plaintiff made progress in settlement discussions on December 1,
2016, and City expects Plaintiff to present a counter-offer/proposal that, if accepted, would resolve the

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STIPULATION TO CONTINUE DISCOVERY DEADLINE FOR THE SOLE PURPOSE OF
TAKING ONE ADDITIONAL DEPOSITION; [PROPOSED] ORDER

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entirety of this dispute without further litigation and associated fees. At the very least, City’s counsel is

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required to present the written counter-offer/proposal to the City Council, which meets on December 21,

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2016.

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If the Court grants this extension, the parties have agreed to re-schedule the deposition for

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December 23, 2016, which is the next date available for Plaintiff and counsel.
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Based on the foregoing, the parties respectfully request that the discovery cut-off is continued to
December 23, 2016, for the sole purpose of taking Plaintiff’s deposition.

DATED: December 2, 2016

LEMIEUX & O'NEILL

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/s/ Michael Silander
By___________________________________
Michael Silander
Attorneys for Defendant
City of Ridgecrest

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DATED: December 2, 2016

POTTER, HANDY

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/s/ Raymond Ballister
By___________________________________
Raymond Ballister
Attorneys for William Johnson

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STIPULATION TO CONTINUE DISCOVERY DEADLINE FOR THE SOLE PURPOSE OF
TAKING ONE ADDITIONAL DEPOSITION; [PROPOSED] ORDER

[PROPOSED] ORDER

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The current discovery cut-off is December 12, 2016. For good cause shown, the request to take
the plaintiff’s deposition on December 23, 2016, despite the expiration of the discovery deadline, is
GRANTED.

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IT IS SO ORDERED.
Dated:

December 2, 2016

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO CONTINUE DISCOVERY DEADLINE FOR THE SOLE PURPOSE OF
TAKING ONE ADDITIONAL DEPOSITION; [PROPOSED] ORDER