Haynes, et al v. Johnson, et al

Filing 22

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 6/17/2016 ORDERING that the following deadlines are CONTINUED: Non-expert Discovery Completion continued to 9/6/2016; Expert Disclosures continued to 8/1/2016; Rebuttal Expert Disclos ure continued to 8/21/2016; Expert Discovery Completion continued to 10/18/2016; Motion Hearing Schedule (for filing) continued to 12/19/2016; Final Pretrial Conference continued to 2/27/2017 at 09:00 AM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. Jury Trial continued to 4/25/2017 at 09:00 AM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Zignago, K.)

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JOHN L. BURRIS, State Bar No. 69888
DEWITT M. LACY, State Bar No. 258789
The Law Offices of John L. Burris
7677 Oakport Street, Suite 1120
Oakland, CA 94621
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
JOHN M. LUEBBERKE, City Attorney
State Bar No. 164893
JAMES F. WILSON, Deputy City Attorney
State Bar No. 107289
TED DANIEL WOOD, Deputy City Attorney
State Bar No. 191768
425 N. El Dorado Street, 2nd Floor
Stockton, CA 95202
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
ROBERT JOHNSON, WILLIAM KAMBIC, DANA MOSHER, and RYAN MORRIS
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SYLVIA HAYNES, et al.,
Plaintiffs,

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vs.
ROBERT JOHNSON, et al.,
Defendants.

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Case No. 2:15-CV-00565-WBS-CKD
STIPULATION AND ORDER FOR
CONTINUANCE OF PRETRIAL
SCHEDULING ORDER DEADLINES,
INCLUDING TRIAL
Assigned: Hon. William B. Shubb
Assigned: Hon. Carolyn K. Delaney, United States
Magistrate Judge
Complaint Filed: March 13, 2015
Trial Date: November 8, 2016

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IT IS HEREBY STIPULATED by and between Plaintiffs SYLVIA HAYNES,

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individually

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ANNTIONETT HAYNES, individually; THE ESTATE OF DONALD RAY HAYNES, and

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Defendants

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RYAN MORRIS, by and through their counsel of record, DeWitt Lacy, Law Offices of John

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Burris; and Defendants, City of Stockton, et al., by and through attorneys of record, Ted Wood,

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Office of the City Attorney, that the following deadlines be continued:

and

as

ROBERT

successor-in-interest

JOHNSON,

to

WILLIAM

Decedent

DONALD

KAMBIC,

DANA

RAY

HAYNES;

MOSHER,

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STIPULATION AND ORDER FOR CONTINUANCE OF PRETRIAL SCHEDULING DEADLINE

and

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Non-expert Discovery Completion

September 6, 2016 (Prior date was June 6, 2016)

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Expert Disclosures

August 1, 2016 (Prior date was April 25, 2016)

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Rebuttal Expert Disclosure

August 21, 2016 (Prior date was May 20, 2016)

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Expert Discovery Completion

October 18, 2016 (Prior date was June 6, 2016)

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Motion Hearing Schedule (for filing) December 19, 2016 (Prior date was June 24, 2016)

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Final Pretrial Conference

February 27, 2017 at 9:00 a.m.
(Prior date was September 12, 2016)

Jury Trial

April 25, 2017 at 9:00 a.m.
(Prior date was November 8, 2016)

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The brief continuance is requested to permit counsel for Plaintiffs to file and have heard a

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motion to withdraw as counsel and to permit Plaintiffs the opportunity to either secure new

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counsel or prepare to try their case in pro per. The continuance is also requested as there remain

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several outstanding discovery issues that will need to be addressed following counsel’s motion to

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withdraw. The parties respectfully request the Court grant this stipulation to allow them adequate

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time to prepare the case for trial.
IT IS SO STIPULATED.

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Dated: May31, 2016

JOHN M. LUEBBERKE
CITY ATTORNEY

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BY

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/s/ Ted Daniel Wood
TED DANIEL WOOD
Deputy City Attorney
Attorneys for Defendants
CITY OF STOCKTON, et al.

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Dated: May 31, 2016

LAW OFFICES OF JOHN L. BURRIS

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By

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/s/ Dewitt M. Lacy__
DEWITT M. LACY
Attorneys for Plaintiffs

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STIPULATION AND ORDER FOR CONTINUANCE OF PRETRIAL SCHEDULING DEADLINE

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ORDER

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In accordance with the parties’ stipulation, and good cause appearing, the deadline for the

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completion of discovery, expert discovery, the motion hearing schedule, the final pretrial

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conference, and the trial date specified above are continued with the foregoing request.

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IT IS SO ORDERED.

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Dated: June 17, 2016

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STIPULATION AND ORDER FOR CONTINUANCE OF PRETRIAL SCHEDULING DEADLINE