Wagner et al v. City of Stockton Police Department, et al

Filing 31

STIPULATION and ORDER 30 extending deadline signed by Magistrate Judge Edmund F. Brennan on 1/13/2016. Court, having considered foregoing Stipulation of parties, and good cause appearing therefor, it is ORDERED deadline for fact Discovery, is EXTENDED to 3/30/2016. Motions to Compel Discovery must beheard no later than 3/2/2016. (Marciel, M)

Che L. Hashim, Esq. (SBN 238565)
861 Bryant Street
San Francisco, CA 94103
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiffs
THOMAS WAGNER
TAMMY WAGNER
Ted Daniel Wood (SBN 191768)
Office of the City Attorney
City of Stockton
425 North El Dorado Street
Stockton, CA 95202-1977
Tel: [phone]
Fax: [phone]
Attorney for Defendants
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

THOMAS WAGNER
TAMMY WAGNER,

Case No. 2:11-cv-02490 EFB

Plaintiffs,
vs.
CITY OF STOCKTON, a municipal
corporation; BLAIR ULRING, in his
capacity of chief of police for CITY OF
STOCKTON; MARK BERG (Stockton
Police Department Star #0486); JEFFERY
TACAZON (Stockton Police Department
Star #1395); MICHELLE GUTHRIE
(Stockton Police Department Star #1524);

STIPULATION AND [PROPOSED]
ORDER TO AMEND THE
SCHEDULING ORDER TO EXTEND
THE FACT DISCOVERY DEADLINE
AND DEADLINE FOR ANY MOTION
TO COMPEL DISCOVERY, EACH BY 30
DAYS.

Defendants.

1
Case No. 2:11-cv-02490 EFB
STIPULATION AND [PROPOSED] ORDER TO AMEND THE SCHEDULING ORDER TO EXTEND THE FACT
DISCOVERY DEADLINE AND DEADLINE FOR ANY MOTION TO COMPEL DISCOVERY, EACH BY 30 DAYS.

On July 2, 2012 a Notice of Automatic Stay pursuant to 11 U.S.C. § 362(a) was filed
following the City of Stockton’s entrance into a Chapter 9 bankruptcy proceeding (Case No
2012-32118) in the United States Bankruptcy Court for the Eastern District of California. On
May 28, 2015, the state was lifted.
On July 17, 2015, this case was reassigned to the Honorable Edmund F. Brennan,
Magistrate Judge. On August 12, 2015, the court issued an amended pretrial scheduling order
in this case, setting the dates currently sought continued by this stipulated request. The parties
have sought to renew discovery after some years of dormancy due to the bankruptcy stay and
request a short amount of time to conclude discovery. The requested amendments to the
pretrial scheduling order will not have any effect on the remaining dates, including the October
18, 2016 trial date.
IT IS THEREFORE STIPULATED by and between all parties to this stipulation, by and
through their respective attorneys that the deadline for fact discovery, currently February 29,
2016, be extended to March 30, 2015, and that the deadline to hear bring any motion to compel
discovery, currently set for February 3, 2016, to be extended to March 4, 2016.

Dated: January 13, 2016

Respectfully Submitted,
/s/ Che L. Hashim
Che L. Hashim
Attorney for Plaintiffs
THOMAS WAGNER, TAMMY WAGNER

Dated: January 13, 2016

Respectfully Submitted,
/s/Ted Daniel Wood
Ted Daniel Wood
Attorney for Defendants
CITY OF STOCKTON, BLAIR ULRING

2
Case No. 2:11-cv-02490 EFB
STIPULATION AND [PROPOSED] ORDER TO AMEND THE SCHEDULING ORDER TO EXTEND THE FACT
DISCOVERY DEADLINE AND DEADLINE FOR ANY MOTION TO COMPEL DISCOVERY, EACH BY 30 DAYS.

ORDER
The Court, having considered the foregoing stipulation of the parties, and good cause
appearing therefor, the Court hereby orders that the deadline for fact discovery, currently
February 29, 2016, be extended to March 30, 2016. Motions to compel discovery must be
heard no later than March 2, 2016. As modified, it is so ordered.
Dated: January 13, 2016.

3
Case No. 2:11-cv-02490 EFB
STIPULATION AND [PROPOSED] ORDER TO AMEND THE SCHEDULING ORDER TO EXTEND THE FACT
DISCOVERY DEADLINE AND DEADLINE FOR ANY MOTION TO COMPEL DISCOVERY, EACH BY 30 DAYS.