De Jesus-Edmunson v. City of Sacramento

Filing 14

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 3/24/2016 ORDERING that the Court GRANTS a continuance of the trial and pretrial deadlines as follows: Trial set for 11/27/2017 at 9:00 AM; Final Pretrial Conference set for 9/21/2017 at 2:00 PM; Last Date to Hear Dispositive Motions is 6/1/2017; Discovery cutoff is 12/27/2016; Designation of expert witnesses due 2/21/2017. (Zignago, K.)

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Anthony Goldsmith, Esq. (State Bar #: 125621)
LAW OFFICES OF ANTHONY E. GOLDSMITH
1841 Arteique Road
Topanga, CA 90290
Tel.: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorney for Plaintiff, CYNTHIA DE JESUS-EDMUNSON
Steven L. Derby, Esq. (State Bar # 148372)
THE DERBY LAW FIRM
1255 Treat Blvd., Suite 300
Walnut Creek, CA 94597
Tel.: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorney for Plaintiff, CYNTHIA DE JESUS-EDMUNSON
Katherine E. Underwood, Esq. (State Bar # 249308)
CITY OF SACRAMENTO
915 I St., 4th Floor
Sacramento, CA 95814
Tel.: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorney for Defendant, CITY OF SACRAMENTO
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
CYNTHIA DE JESUS-EDMUNSON, )
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Plaintiff,
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vs.
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CITY OF SACRAMENTO; and
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DOES 1-50, Inclusive,
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Defendants.
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_______________________________ )
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CASE NO. 2:15-cv-00550-TLN-CKD
Civil Rights
[The Honorable Troy L. Nunley]
STIPULATION TO CONTINUE
TRIAL DATE AND PRETRIAL
DEADLINES; ORDER
Current Trial Date: 5/22/2017
Proposed Trial Date: 11/20/2017
Current Final Pretrial Conference: 3/23/2017
Proposed Final Pretrial Conference: 9/25/2017
Current Discovery Completion Date: 6/24/2016
Proposed Discovery
Completion Date: 12/27/2016

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1
STIPULATION TO CONTINUE TRIAL DATE AND PRETRIAL DEADLINES AND ORDER

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Plaintiff, CYNTHIA DE JESUS-EDMUNSON, and Defendant, CITY OF

2 SACRAMENTO, by and through their respective attorneys, Anthony E.
3 Goldsmith, Steven L. Derby, and Katherine E. Underwood, hereby jointly stipulate
4 and request the trial date and pretrial deadlines in this to be continued for good
5 cause as shown below. Presently, trial in this case is scheduled to begin on May
6 22, 2017. This first request for an extension of time is based on the following good
7 cause:
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1. On March 11, 2015, Plaintiff, by and through counsel, filed her Complaint

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for damages and injunctive relief, arising out of an incident that occurred on

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or about, February 20, 2014, which involves the alleged deprivation of

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Plaintiff’s civil rights, as well as personal injuries.

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2. The parties have both discovered and agree there are factual issues in

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contention that don’t involve the physical condition of the city’s public

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rights of way and that discovery should be done in phases. Therefore, both

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parties wish to extend time for Discovery, specifically in regards to technical

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issues involving the city’s public rights of way.

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3. This is the first request for an extension and although both parties

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understand the importance of keeping the Court’s timeline, all involved are

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working together cooperatively and believe the extensions will likely result

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in settlement, as opposed to having to proceed to trial.

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4. Based on the foregoing, the parties jointly stipulate and request that the

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Court continue the current trial date from May 22, 2017, to November 20,

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2017.

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5. That the current final pretrial conference be continued from March 23, 2017,
to September 25, 2017.

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STIPULATION TO CONTINUE TRIAL DATE AND PRETRIAL DEADLINES AND ORDER

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6. That the associated deadlines be continued as follows:

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a. Trial:

November 20, 2017

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b. Final Pretrial Conference:

September 25, 2017

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c. Joint Final Pretrial Conference Statement:

September 18, 2017

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d. Filing of Trial Brief:

November 6, 2017

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e. Last Date to Hear Dispositive Motions:

June 5, 2017

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f. Non-Expert Discovery Cutoff (Fact):

December 27, 2016

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g. Expert Disclosure (Initial):

February 21, 2017

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h. Expert Disclosure (Rebuttal):

March 17, 2017

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i. Expert Discovery Cutoff:

April 7, 2017

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13 IT IS SO STIPULATED
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DATED: March 23, 2016
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LAW OFFICES OF ANTHONY E.
GOLDSMITH

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By: /s/ Anthony Goldsmith
Anthony E. Goldsmith

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Attorney for Plaintiff,

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CYNTHIA DE JESUS-EDMUNSON

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DATED: March 23, 2016
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THE DERBY LAW FIRM
By: /s/ Steven Derby

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Steven Derby

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Attorney for Plaintiff,

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CYNTHIA DE JESUS-EDMUNSON

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3
STIPULATION TO CONTINUE TRIAL DATE AND PRETRIAL DEADLINES AND ORDER

1 DATED: March 23, 2016
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CITY OF SACRAMENTO
By: /s/ Katherine Underwood

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Katherine E. Underwood

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Attorney for Defendant,

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CITY OF SACRAMENTO

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4
STIPULATION TO CONTINUE TRIAL DATE AND PRETRIAL DEADLINES AND ORDER

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ORDER

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Pursuant to the parties’ Stipulation to Continue Trial Date and Pretrial Deadlines, and

3 for good cause shown, the Court hereby GRANTS a continuance of the trial and pretrial
4 deadlines as follows:
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a. Trial:

November 27, 2017, at 9:00 a.m.

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b. Final Pretrial Conference:

September 21, 2017, at 2:00 p.m.

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c. Joint Final Pretrial Conference Statement:

September 14, 2017

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d. Filing of Trial Brief:

November 13, 2017

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e. Last Date to Hear Dispositive Motions:

June 1, 2017

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f. Non-Expert Discovery Cutoff (Fact):

December 27, 2016

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g. Expert Disclosure (Initial):

February 21, 2017

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h. Expert Disclosure (Rebuttal):

March 17, 2017

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i. Expert Discovery Cutoff:

April 7, 2017

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17 Dated: March 24, 2016
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Troy L. Nunley
United States District Judge

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STIPULATION TO CONTINUE TRIAL DATE AND PRETRIAL DEADLINES AND ORDER