Novo v. Ashby et al

Filing 103

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 09/01/16 ORDERING that the deadline for filing the Joint Statement of Disputed and Undisputed Facts and Plaintiff's Exhibit List is EXTENDED to 09/15/16. (Benson, A)

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ROBERT F. KOEHLER, JR. SBN 80278
HIBBITT TARBELL & KOEHLER
331 "J" Street, Suite 200
Sacramento, CA 95814-2220
916-446-7858;
Email: [e-mail]
Attorney for Sarah R. Novo, Plaintiff

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SARAH R. NOVO,
Plaintiff,
v.
CITY OF SACRAMENTO, ANGELIQUE
ASHBY,
Defendants.

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Case No.: 2:13-CV-00521-MCE-AC
STIPULATION AND ORDER TO
EXTEND DUE DATE FOR FILING THE
JOINT STATEMENT OF DISPUTED AND
UNDISPUTED FACTS AND PLAINTIFF’S
EXHIBIT LIST

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The parties, Plaintiff Sarah R. Novo (“Plaintiff”) and Defendants City of

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Sacramento and Angelique Ashby (“Defendants”), through their respective attorneys

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of record, hereby move the court for a 14 day extension to file the Joint Statement of

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Disputed and Undisputed Facts and Plaintiff’s Exhibit List. Currently, the deadline

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set by the Court is September 1, 2016.

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The reason for this request is that Plaintiff’s counsel’s health has deteriorated

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significantly this past weekend. Counsel Robert F. Koehler Jr. suffers from Wegner’s

STIPULATION REQUESTING EXTENSION; ORDER THEREON
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Disease and has recently relapsed. If left untreated, Mr. Koehler may suffer

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permanent kidney damage. His doctors have advised him to have a Rituxan

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(rituximab) infusion as early as possible based on his recent lab reports. The

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infusion has been moved up to August 31, 2016. Given this unexpected health

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crisis, plaintiff is unable to complete her Joint Statement of Disputed and

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Undisputed Facts or her Exhibit List by September 1, 2016. (Please see attached

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letter from Dr. David Lehman dated August 30, 2016.) Without plaintiff’s input, the

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parties cannot file a Joint Statement of Disputed and Undisputed Issues by the court

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ordered deadline of September 1, 2016.

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Therefore, the parties respectfully request that the Court extend the current
deadline to September 15, 2016.
SO STIPULATED. DATED: August 31, 2016

Respectfully submitted,

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HIBBITT TARBEL & KOEHLER

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BY:

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/s/ ROBERT F. KOEHLER
ROBERT F. KOEHLER
Attorney for Plaintiff

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DATED: August 31, 2016

KATHLEEN T. ROGAN
City Attorney

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BY:

/s/ KATHLEEN T. ROGAN
KATHLEEN T. ROGAN
Senior Deputy City Attorney
Attorneys for Defendants

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STIPULATION REQUESTING EXTENSION; ORDER THEREON
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ORDER

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In accordance with the foregoing stipulation, and good cause appearing, the

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deadline for filing the Joint Statement of Disputed and Undisputed Facts and

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Plaintiff’s Exhibit Lis is hereby extended from September 1, 2016 to September 15,

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2016.
IT IS SO ORDERED.

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Dated: September 1, 2016

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STIPULATION REQUESTING EXTENSION; ORDER THEREON
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