Shannon v. County of Sacramento

Filing 70

STIPULATION and ORDER signed by Magistrate Judge Deborah Barnes on 4/4/2017 ORDERING that the deadline for fact discovery, previously set for 5/15/2017, is VACATED and RESET for 5/19/2017, with all other dates in the scheduling order entered on 11/3/2016 remaining unchanged. (Zignago, K.)

LUCERO LAW FIRM, APC
3517 CAMINO DEL RIO SOUTH, STE. 200, SAN DIEGO, CA 92108
Telephone: [phone]; Facsimile: [phone]

LUCERO LAW FIRM, APC
1 Estevan R. Lucero, Esq. (SBN 298076)
[e-mail]
2 3517 Camino Del Rio South, Ste. 200
San Diego, CA 92108
3 Telephone: [phone]
Facsimile: [phone]
4
Attorney for Plaintiff,
5 SALVADOR SHANNON, an individual,
6 CREGGER & CHALFANT LLP
ROBERT L. CHALFANT, SBN 203051
7 Email: [e-mail]
WENDY MOTOOKA, SBN 233589
8 Email: [e-mail]
701 University Avenue, Suite 110
9 Sacramento, CA 95825
Phone: [phone]
10 Fax: [phone]
11 Attorneys for Defendants COUNTY OF
SACRAMENTO, TIMOTHY JONES,
12 and JOSEPH REEVE
13
UNITED STATES DISTRICT COURT
14
EASTERN DISTRICT OF CALIFORNIA
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No. 2:15-cv-00967-KJM-DB
16 SALVADOR SHANNON, an
individual,
STIPULATION AND ORDER
17
Plaintiff,
MODIFYING SCHEDULING ORDER
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v.
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SACRAMENTO COUNTY, a
20 government entity; TIMOTHY
JONES, an individual; and JOSEPH
21 REEVE, an individual,
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Defendant.
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24 TO THE ABOVE-ENTITLED COURT:
25

The parties, by and through their attorneys of record, jointly request that the

26 Court modify the current scheduling order as set forth herein.
WHEREAS on November 24, 2014 an action was commenced in the Superior
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28 Court of the State of California in and for the County of Sacramento, entitled
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STIPULATION AND ORDER MODIFYING SCHEDULING ORDER

1 Salvador Shannon, Plaintiff, v. County of Sacramento, DOES 1 to 20, Defendants,
2 Case No. 34-2014-00172136;
3

WHEREAS Plaintiff’s complaint was removed to this Court by Defendants

4 pursuant to 28 U.S.C. § 1441(a);
5

WHEREAS on May 11, 2016, Plaintiff filed a Fifth Amended Complaint;

6

WHEREAS on June 1, 2016, Defendants answered the complaint;

7

WHEREAS the Court’s scheduling order was entered on June 7, 2016, and

LUCERO LAW FIRM, APC
3517 CAMINO DEL RIO SOUTH, STE. 200, SAN DIEGO, CA 92108
Telephone: [phone]; Facsimile: [phone]

8 modified once by stipulated order on November 3, 2016;
9

WHEREAS pursuant to the current scheduling order, fact discovery is to be

10 completed by May 15, 2017;
11

WHEREAS the parties previously had the depositions of the Defendants and

12 five other officers scheduled to take place on March 15, 16, and 17, 2017;
13

WHEREAS during the week preceding these depositions, counsel for Plaintiff

14 learned of a last minute trial conflict that caused him to have to postpone these
15 depositions;
16

WHEREAS the parties have been able to reschedule most, but not all, of the

17 depositions within the time remaining for fact discovery;
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WHEREAS the parties anticipate being able to complete all of the depositions

19 by May 19, 2017;
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32

STIPULATION AND ORDER MODIFYING SCHEDULING ORDER

1

THEREFORE, the parties hereby stipulate, by and through their counsel of

2 record, as follows:
3

1.

That the current scheduling order be modified to extend fact discovery

4 to May 19, 2017, an additional five (5) days past the current cut-off date of May 15,
5 2017;
6

2.

That all other dates in the pretrial scheduling order remain unchanged.

7 IT IS SO STIPULATED AND REQUESTED BY THE PARTIES.
LUCERO LAW FIRM, APC
3517 CAMINO DEL RIO SOUTH, STE. 200, SAN DIEGO, CA 92108
Telephone: [phone]; Facsimile: [phone]

8
9 DATED: March 24, 2017
10

LUCERO LAW FIRM, APC
By: /s/ Estevan R. Lucero
Attorney for Plaintiff,
Gabriel Napier, by and through his
guardian ad litem, Lilly Quiroz
E-mail: [e-mail]

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13
14 DATED: March 24, 2017
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CREGGER & CHALFANT LLP
By: /s/ Wendy Motooka
Attorneys for Defendants County of
Sacramento, Joseph Reeve, and Timothy
Jones
E-mail: [e-mail]

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STIPULATION AND ORDER MODIFYING SCHEDULING ORDER

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ORDER
Pursuant to the parties’ stipulation, (ECF No. 69), IT IS HEREBY ORDERED

3 THAT the deadline for fact discovery, previously set for May 15, 2017, is
4 VACATED and RESET for May 19, 2017, with all other dates in the scheduling
5 order entered on November 3, 2016 remaining unchanged.
6

LUCERO LAW FIRM, APC
3517 CAMINO DEL RIO SOUTH, STE. 200, SAN DIEGO, CA 92108
Telephone: [phone]; Facsimile: [phone]

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8 Dated: April 4, 2017
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DLB:6
DB\orders\orders.civil\shannon0967.stip.disc.eot.ord

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STIPULATION AND ORDER MODIFYING SCHEDULING ORDER