Townsend v. Sisto et al

Filing 90

STIPULATION and ORDER 89 for extension of time signed by Magistrate Judge Carolyn K. Delaney on 8/11/2015. Parties are actively engaged in settlement negotiations. Should negotiations fail, plaintiff would be potentially denied opportunity to complete Discovery. Parties stipulate terms of Court's 88 Order are EXTENDED to 9/4/2015. Any Motion to Compel must be filed no later than 11/4/2015. (Marciel, M)

1

5

LAW OFFICE OF KEN I. KARAN
Ken I. Karan, Esq.
State Bar Number 204843
2907 Shelter Island Drive, Ste. 105-215
San Diego, California 92106
Telephone: [phone]
Facsimile: 866 841 5420

6

ATTORNEY FOR PLAINTIFF WILLIAM TOWNSEND, JR.

2
3
4

7
8

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA

9
10

WILLIAM TOWNSEND, JR.,

Plaintiff,

11
12

vs.

13
14

D.K. SISTO, T. CHERRY, M. JUNKER,
AND V. SINGH,

15

Defendants.

16

) Civil Action, File No.: 2:09-cv-02342-CKD
)
)
)
) STIPULATION OF THE PARTIES
)
)
)
)
) Judge: The Hon. Carolyn K. Delaney
)
)
)
)

17

Plaintiff William Townsend, Jr., by and through counsel Ken I. Karan, Esq., and

18
19
20

Defendants D.K. Sisto, T. Cherry, M. Junker, and V. Singh, by and through counsel James
Walter, Esq., agree as follows:

21
22
23
24

1.

Discovery is proceeding pursuant to the Court’s March 26, 2015, order, and as modified

by the stipulation and order accepted by the Court. (ECF 88.)
2.

The parties are actively engaged in settlement negotiations.

3.

As a result, Plaintiff took his scheduled depositions of Defendants off calendar in order

25
26
27

to make the negotiations meaningful.

28

STIPULATION OF THE PARTIES - 1

1
2
3

4.

Should negotiations fail, Plaintiff would be potentially denied the opportunity to

complete discovery.
5.

The parties herein stipulate to extend the terms of the Court’s order for 28 days making

4
5
6
7

the new deadline to depose defendants, serve discovery and serve subpoenas Friday,
September 4, 2015.
6. Any motion to compel must be filed no later than November 4, 2015.

8
9
10

So stipulated,
Date:

8/7/15

Signed:

/s/Ken Karan
Ken I. Karan, Esq.

Date:

8/7/15

Signed:

/s/James Walter
James Walter, Esq.

11

.

12
13
14
15
16
17
18
19
20

IT IS SO ORDERED.
Dated: August 11, 2015
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

21
22
23
24
25
26
27
28

STIPULATION OF THE PARTIES - 2

.