Koch v. Sacramento County et al

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 7/6/2016 and agreed between the parties to MODIFY the Discovery and Scheduling Order. Dispositive Motions shall be filed on or before 8/8/2016. (Yin, K)

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A PROFESSIONAL CORPORATION
David A. Melton, SBN 176340
Colleen R. Howard, SBN 257661
Taylor W. Rhoan, SBN 294941
350 University Avenue, Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]

Attorneys for Defendant
SCOTT JONES

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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PORTER | SCOTT

350 University Avenue, Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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Roland Thomas Koch,

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Plaintiff,

CASE NO. 2:15-cv-00739-JAM-CKD
STIPULATION AND ORDER TO
MODIFY SCHEDULING ORDER

v.
SACRAMENTO COUNTY; SCOTT
JONES, Sheriff of Sacramento County, in
his individual and official capacity; John
Doe 1 “Booking Officer”; John Doe 2
“Classification Officer”; John Does 3-10 “4th
Fl. Officers”; John Doe 11 “Classification
Officer”; John Doe 12 “Facility
Commander”; John Does 13-20 “7th Fl.
Officers”; John Doe 21 “Supervisor”; John
Does 22-29 “3rd Fl. Officers”; John Doe 30,
Bdg# 1039? “Supervisor”; John Doe 31,
Bdg# 589? “Supervisor” in their individual
and official capacities;
Defendants.
____________________________________/

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{01573001.DOCX}

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STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER

IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ROLAND

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THOMAS KOCH, in Pro Per, and Defendant SCOTT JONES, pursuant to Local Rule 143 as
follows:
1.

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Scheduling Order to continue the dispositive motion deadline for an additional 30 days, based on
good cause appearing as more fully set forth below.

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deadline

PORTER | SCOTT

350 University Avenue, Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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June

10,

2016.

(Document

13)

The

motions. (Document 17.) No further orders modifying the Discovery and Scheduling Order have
been entered.
3.

The parties are in good faith attempting to resolve this matter and are in the process

of negotiating a settlement. In an attempt to avoid the time and expense of preparing and opposing
a motion for summary judgment, the parties respectfully request that the dispositive motion
deadline be continued for 30 days to allow the parties time to hopefully resolve this matter.
Plaintiff in this matter confirmed with Counsel for Defendant over the telephone that he was in
agreement with the continuance. (See Exhibit A, Declaration of Taylor W. Rhoan filed herewith.)
4.

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for

Court has previously granted one extension of time for 30 days on the deadline to file dispositive

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The Court’s Discovery and Scheduling Order originally set the dispositive motion

2.

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The parties respectfully request that the District Court modify the Discovery and

Therefore, the parties respectfully submit that good cause exists to amend the

dispositive motion deadline of the Discovery and Scheduling Order dated November 30, 2015
(Document 13) and subsequently modified on June 10, 2016 (Document 17) as follows:
Deadline

Old Date

Dispositive motion deadline

July 8, 2016

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August 8, 2016

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New Date

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{01573001.DOCX}

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STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER

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This Stipulation may be signed in counterparts and any facsimile or electronic signature
shall be as valid as an original signature.
IT IS SO STIPULATED.
Dated: July 5, 2016

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By
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//s// Roland Thomas Koch as authorized
ROLAND THOMAS KOCH
Plaintiff in Pro Per

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Dated: July 5, 2016

PORTER SCOTT
A PROFESSIONAL CORPORATION

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By

PORTER | SCOTT

350 University Avenue, Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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//s// Taylor W. Rhoan
Taylor W. Rhoan
Attorney for Defendant
SCOTT JONES

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ORDER
Having reviewed the above stipulation and good cause appearing therefore, IT IS HEREBY
ORDERED that the Discovery and Scheduling Order, be modified with the new schedule as set
forth above.

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IT IS SO ORDERED.
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Dated: July 6, 2016

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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{01573001.DOCX}

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STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER