Barron v. City of Redding et al

Filing 17

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 6/10/15. IT IS HEREBY ORDERED that the 10 Scheduling Order be MODIFIED. Non-Expert Discovery Cutoff is 8/14/15. The Pretrial Conference date of 3/17/16 and Trial date of 5/2/15 remain unchanged. (Meuleman, A)

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Paul Q. Goyette, Esq. SBN 137250
Sean D. O’Dowd, Esq. SBN 296320
Rick E. Snyder, Esq. SBN 173575
GOYETTE & ASSOCIATES, INC.
A Professional Law Corporation
2366 Gold Meadow Way, Suite 200
Gold River, CA 95670
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant, Brandon Largent

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ROBERT BARRON,

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Plaintiff,

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v.

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CASE NO.: 2:14-cv-01107-MCE-CMK
STIPULATED REQUEST TO MODIFY
SCHEDULING ORDER; ORDER
THEREON

CITY OF REDDING, BRANDON
LARGENT, CHIEF ROBERT F.
PAOLETTI, and DOES 1-10,

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Defendants.

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ROBERT BARRON,

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and Defendants CITY OF REDDING, BRANDON LARGENT, and CHIEF ROBERT F.

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PAOLETTI, (collectively, the “Parties”), by and through their undersigned Counsel, pursuant to Local

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Rules 143 and 144 as follows:
1.

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The Parties respectfully request the District Court modify the Scheduling Conference

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Order to allow approximately 40 additional days to complete non-expert discovery based on good

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cause appearing therefore as more fully set forth below. The Final Pretrial and Trial dates would

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remain the same.

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2.

On November 19, 2014 the Court issued its Initial Scheduling Order setting certain

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dates and deadlines, including discovery cut-offs, dispositive motion hearing deadlines and trial. Dckt.

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No. 10.
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STIPULATED REQUEST TO MODIFY SCHEDULING ORDER; ORDER THEREON

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3.

The Parties seek modification of the dates currently set for the close of non-expert

discovery.
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The Parties submit good cause exists to modify the current scheduling order due to

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counsels’ respective schedules, and the remaining voluminous discovery that must be completed. The

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Parties have met and conferred regarding the discovery issues and deposition scheduling, and have

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agreed that approximately 40 additional days will be necessary to resolve the pending discovery issues

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and complete non-expert and expert discovery.

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5.

The Parties submit that the movement of dates will allow counsel to properly complete

non-expert discovery. The Parties submit that the proposed modified dates will not affect the Pretrial
Scheduling Conference or trial date.
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Therefore, the Parties respectfully submit that good cause exists to amend the Pretrial

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Scheduling Order dated November 19, 2014, and hereby propose the following schedule for further

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proceedings:
Current Date

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Proposed Date

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Expert Disclosure:

September 2, 2015

Unchanged

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Non-Expert Discovery Cutoff:

July 2, 2015

August 14, 2015

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Supplemental Expert Disclosure:

September 22, 2015

Unchanged

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Expert Discovery Cutoff:

November 13, 2015

Unchanged

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Pretrial Motion Filing Deadline:

November 13, 2015

Unchanged

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Pretrial Motion Hearing Deadline:

January 7, 2016

Unchanged

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Final Pretrial Conference:

March 17, 2016

Unchanged

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Trial:

May 2, 2016

Unchanged

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IT IS SO STIPULATED, BY AND THROUGH COUNSEL OF RECORD.

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Dated: June 3, 2015.

LAW OFFICES OF DALE K. GALIPO

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By:

/s/ Dale K. Galipo
Dale K. Galipo, Esq.

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STIPULATED REQUEST TO MODIFY SCHEDULING ORDER; ORDER THEREON

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Dated: June 3, 2015.

LAW OFFICES OF VICKI I. SARMIENTO

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By:
/s/ Vicki I. Sarmiento
Vicki I. Sarmiento, Esq.

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Dated: June 3, 2015.

BRICKWOOD LAW OFFICE

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By:

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Dated: June 3, 2015.

/s/ Gary Brickwood
Gary Brickwood, Esq.

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GOYETTE & ASSOCIATES, INC.
A Professional Law Corporation

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By:

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/s/ Sean D. O’Dowd
Sean D. O’Dowd, Esq.

ORDER

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Having reviewed the above stipulation and good cause appearing therefore, IT IS HEREBY

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ORDERED that the Scheduling Conference Order be modified as follows:

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Expert Disclosure:

September 2, 2015

(Unchanged)

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Non-Expert Discovery Cutoff:

August 14, 2015

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Supplemental Expert Disclosure:

September 22, 2015 (Unchanged)

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Expert Discovery Cutoff:

November 13, 2015

(Unchanged)

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Pretrial Motion Filing Deadline:

November 13, 2015

(Unchanged)

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Pretrial Motion Hearing Deadline:

January 7, 2016

(Unchanged)

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The Pretrial Conference date of March 17, 2016 at 2:00 p.m. in Courtroom 7, before the

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Honorable Morrison C. England, Jr., and trial date of May 2, 2016 at 9:00 a.m. in Courtroom 7, before

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the Honorable Morrison C. England, Jr., remain unchanged.

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IT IS SO ORDERED.
Dated: June 10, 2015

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STIPULATED REQUEST TO MODIFY SCHEDULING ORDER; ORDER THEREON