Bel Montez, et al., v. City of Stockton et al

Filing 35

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr. on 02/291/6 ORDERING that the following deadlines are RESET: Discovery completed by 6/1/2016; Designation of Expert Witnesses due by 8/1/2016 with any supplemental expert disclosure due 08/20/16; last day to hear dispositive motions is 11/15/2016. All other dates and deadlines set forthin Court's Second Amended Pretrial Scheduling Order remain in full force and effect. (Benson, A)

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JOHN L. BURRIS, ESQ. SBN 69888
BENJAMIN NISENBAUM, ESQ. SBN 222173
JAMES COOK, ESQ, SBN 300212
LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Centre
7677 Oakport Street, Suite 1120
Oakland, California 94621
[phone]
Attorney for Plaintiff
ISABEL BEL MONTEZ
JOSEPH GARCIA SR.

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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ISABEL BEL MONTEZ, et al.
Plaintiff,

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Case No. 2:10-cv-03149 MCE EFB
STIPULATION AND ORDER FOR
CONTINUANCE OF PRETRIAL
SCHEDULING ORDER DEADLINES

vs.
CITY OF STOCKTON, a municipal
corporation; CITY OF STOCKTON POLICE
DEPARTMENT; BLAIR ULRING in his
capacity as CHIEF OF POLICE for the CITY
OF STOCKTON POLICE DEPARTMENT;
DOES 1-100, inclusive; individually and in their
capacities as POLICE OFFICERS for CITY OF
STOCKTON POLICE DEPARTMENT.

Judge: United States Magistrate Judge Edmund
F. Brennan
Complaint Filed: November 22, 2010
Trial: March 13, 2017

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Defendants.
/

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IT IS HEREBY STIPULATED by and between Plaintiffs, through attorneys of record,

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JAMES COOK, and BEN NISENBAUM, Law Offices of John Burris; and Defendants, CITY OF

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STOCKTON, et al., by and through attorneys of record TED DANIEL WOOD, that the following

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deadlines be continued:

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Discovery Completion:

June 1 2016 (Prior date was March 14, 2016)

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Expert Disclosure:

August 1, 2016 (Prior date was May 13, 2016)

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Supplemental Expert Disc:

August 20, 2016 (Prior date was June 2, 2016)
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Last Day for Dispositive Motions:

November 15, 2016 (Prior date was September 15,

2016).
All other dates remain as set forth in the Court’s Second Amended Pretrial Scheduling Order
(Document 23).
The Court requested that Plaintiffs’ counsel show good cause for a continuance. Plaintiffs’

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counsel assert that there is good cause for a continuance, because until recently we had no contact

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with the client. Without client contact, we could not secure verification signatures to accompany

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discovery responses. The extra time is necessary to allow time for Plaintiffs’ counsel to establish

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consistent communication with minors I.G. and J.G. as well as determine whether they wish to

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continue pursuing the case.
IT IS SO STIPULATED.
Dated: February 29, 2016

By: /s/ James Cook
James Cook
Law Offices of John Burris
Attorney for Plaintiff

Dated: February 29, 2016

By: /s/ Ted Daniel Wood
Ted Daniel Wood
City of Stockton
Attorney for Defendant

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ORDER
In accordance with the parties’ stipulation, and good cause appearing, the deadlines specified

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above are continued in accordance with the foregoing request. All other dates and deadlines set forth
in Court’s Second Amended Pretrial Scheduling Order remain in full force and effect.
IT IS SO ORDERED.
Dated: February 29, 2016

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