De Jesus-Edmunson v. City of Sacramento

Filing 20

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 5/5/2017 CONTINUING discovery cut-off date to 9/14/2017. (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)
SACRAMENTO CITY ATTORNEY’S OFFICE
915 I St., 4th Floor
Sacramento, CA 95814
Tel.: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorney for Defendant, CITY OF SACRAMENTO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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STIPULATION AND
ORDER CONTINUING FACT
DISCOVERY DEADLINES

Plaintiff,

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Case No.: 2:15-CV-00550-TLN-CKD

CYNTHIA DE JESUS-EDMUNSON,

vs.
CITY OF SACRAMENTO; and DOES 150, Inclusive,
Defendants.

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

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SACRAMENTO, by and through their respective attorneys, Anthony E. Goldsmith, Steven

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L. Derby, and Katherine E. Underwood, hereby jointly stipulate and respectfully request the

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trial date and pretrial deadlines in this case to be continued for good cause as shown below.

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Presently, trial in this case is scheduled to begin on June 4, 2018. This request for an

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extension of discovery deadlines is based on the following good cause:
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STIPULATION AND ORDER CONTINUING DISCOVERY DEADLINE

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1.

On March 11, 2015, Plaintiff, by and through counsel, filed her Complaint for

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

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February 20, 2014, which involves the alleged deprivation of Plaintiff’s civil

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rights, as well as personal injuries.

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2.

Plaintiff has endured two serious illnesses unrelated to her injuries allegedly

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sustained in the case before the Court. Additionally, Plaintiff is in the process of

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recovering additional medical records related to this case and both parties want to

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be sure that Defendants have all of Plaintiff’s medical records before taking her

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deposition. Accordingly, the parties ask that the Court to extend the discovery
cut-off date in this case from July 14, 2017 to September 14, 2017.

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3.

This request for an extension of discovery deadlines will not impact the trial date

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or any other discovery and motion dates in the case and although the 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 extension will likely result in

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further settlement discussions, 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 Court

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continue the current discovery cut-off date from July 14, 2017 to September 14,

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2017.

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IT IS SO STPULATED
DATED: May 3, 2017

LAW OFFICES OF ANTHONY E. GOLDSMITH
By: /s/ Anthony Goldsmith
Anthony E. Goldsmith
Attorney for Plaintiff,
CYNTHIA DE JESUS-EDMUNSON

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STIPULATION AND ORDER CONTINUING DISCOVERY DEADLINE

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DATED: May 3, 2017

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By: /s/ Steven Derby
Steven Derby
Attorney for Plaintiff,
CYNTHIA DE JESUS-EDMUNSON

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THE DERBY LAW FIRM

DATED: May 3, 2017

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SACRAMENTO CITY ATTORNEY’S
OFFICE

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By: /s/ Katherine Underwood
Katherine E. Underwood
Attorney for Defendant,
CITY OF SACRAMENTO

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THE STIPULATION OF THE PARTIES IS APPROVED AND IT IS SO
ORDERED.

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Dated: May 05, 2017

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Troy L. Nunley
United States District Judge

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STIPULATION AND ORDER CONTINUING DISCOVERY DEADLINE