Hill v. Fairfield Police Department et al

Filing 31

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr., on 1/10/17 ORDERING that the non-expert discovery cutoff is CONTINUED by 90 days to 3/13/2017. (Kastilahn, A)

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Gregory M. Fox, State Bar No. 070876
Parry A. Black, State Bar No. 291472
BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
Attorneys for Defendants
City of Fairfield, Fairfield Police Department,
Rebecca Belk and Michael Ambrose

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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JEROME HILL,

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Plaintiff,

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Case No. 2:15-cv-01820-MCE-KJN
STIPULATION AND ORDER TO EXTEND TIME
FOR NON-EXPERT DISCOVERY

vs.
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FAIRFIELD POLICE DEPARTMENT; CITY
OF FAIRFIELD, a municipal corporation;
REBECCA BELK, individually and as a Police
Officer for the CITY OF FAIRFIELD;
MICHAEL AMBROSE, individually and as a
Police Officer for the CITY OF FAIRFIELD;
and DOES 1-50,

Hon. Morrison C. England, Jr.

Defendants.

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Plaintiff JEROME HILL and Defendants FAIRFIELD POLICE DEPARTMENT, CITY OF

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FAIRFIELD, REBECCA BELK, and MICHAEL AMBROSE by and through their counsel of record,

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hereby represent to the Court as follows:

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On March 7, 2016, this Court issued a Pretrial Scheduling Order setting, among other deadlines, a
cutoff for fact discovery of December 12, 2016.
The parties have made progress in discovery, including exchanging written discovery, deposing
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STIPULATION CONTINUING NON-EXPERT DISCOVERY CUT-OFF AND ORDER
Hill v Fairfield Police Department, et al., Case No. 2:15-CV-01820-MCE-KJN

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and scheduling depositions of the parties and a witness officer, completing a medical IME of plaintiff,

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and setting a psychiatric IME for January 13, 2017.

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The volume of discovery required, and the schedules of counsel have limited the ability of the

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parties to complete all necessary fact discovery by the set deadline. A 90-day extension of time will

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allow the parties adequate time to conduct full and complete discovery in this case.

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Therefore, the parties request that the non-expert discovery cutoff now set for December 12, 2016

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be continued by 90 days to March 13, 2017.

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IT IS SO STIPULATED:
Dated: December 9, 2016

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BERTRAND, FOX, ELLIOT, OSMAN & WENZEL

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By: /s/Parry A. Black
Gregory M. Fox
Parry A. Black
Attorneys for Defendants
City of Fairfield, Fairfield Police Department,
Rebecca Belk and Michael Ambrose

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Dated: December 9, 2016

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By: /s/ Paul Alaga
Lewis Romero
Paul Alaga
Attorneys for Plaintiff
Jerome Hill

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IT IS SO ORDERED.
Dated: January 10, 2017

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STIPULATION CONTINUING NON-EXPERT DISCOVERY CUT-OFF AND ORDER
Hill v Fairfield Police Department, et al., Case No. 2:15-CV-01820-MCE-KJN