Blight v. Manteca et al

Filing 35

STIPULATION AND ORDER signed by Magistrate Judge Allison Claire on 12/12/2016 ORDERING that all discovery be completed by 2/9/2017. (Michel, G.)

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Jeffrey A. Silvia (SBN 121065)
LAW OFFICE OF JEFFREY A. SILVIA,
A Professional Corporation
2800 West March Lane, Suite 410
Stockton, California 95219
Telephone: [phone]
Facsimile: [phone]
e-mail: [e-mail]
Sanjay S. Schmidt (SBN 247475)
LAW OFFICE OF SANJAY S. SCHMIDT
1388 Sutter Street, Suite 810
San Francisco, CA 94109
Telephone: [phone]
Facsimile: [phone]
e-mail: [e-mail]
Michael F. Babitzke (SBN 50048)
MICHAEL F. BABITZKE, INC.,
A Professional Corporation
6 South El Dorado St., Ste. 305
Stockton, California 95202
Telephone: [phone]
Facsimile: [phone]
e-mail: [e-mail]
Attorneys for Plaintiff,
JOANNE BLIGHT
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION
JOANNE BLIGHT,
Plaintiff,

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vs.
CITY OF MANTECA, a Municipal
Corporation, Manteca Police Department
Detectives ARMANDO GARCIA,
Individually, RANCH JOHNSON,
Individually, KIRK DOTY, Individually,
MIKE KEENER, Individually, IAN
OSBORN, Individually, and ARMEN
AVAKIAN, Individually, Manteca Police

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Case No. 2:15-cv-02513-WBS-AC
STIPULATION & [PROPOSED]
ORDER TO EXTEND DISCOVERY
DEADLINE

Stipulation & [Proposed] Order to Extend Discovery Deadline: Case No. 2:15-cv-02513-WBS-AC

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Department Sergeants PAUL CARMONA
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and CHRIS S. MRAZ, in their Individual and )
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Supervisory capacities, and DOES 1
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THROUGH 60, Jointly and Severally,
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Defendants.
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TO THE CLERK OF THE COURT, ALL PARTIES, AND THEIR ATTORNEYS
OF RECORD:
In its Scheduling Order (Dkt. 8), the Court set various deadlines, which includes a
discovery completion date of January 10, 2017. The parties indicated in their recently filed
stipulation to extend the deadline for expert disclosures that, depending on the circumstances of
the pending discovery related to the CI, they anticipated possibly submitting a request to extend
the discovery deadline. (Dkt. 27, at p. 2, footnote 1.)
Since discovery in this action commenced, the parties have diligently conducted written
discovery and depositions. To date, written discovery has been exchanged, thirteen depositions

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have been conducted, expert disclosures have been made, and some additional depositions to
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address discovery that was the subject of the parties’ recently litigated discovery disagreement
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are on calendar. Nonetheless, as a result of the delays that are inherent in addressing the
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unusual discovery issues involved with this case – and in order to try to the extent possible to
accommodate counsels’ and the deponents’ calendars – it is necessary to extend the discovery
cutoff in this case. For the time being, the parties are hoping that the extension requested in this

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stipulation will allow sufficient time for the completion of discovery in this case, and the

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parties are going to work diligently to accomplish this. The undersigned counsel for Plaintiff

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notes, however, that as of the submission of this stipulation, the CI phase of discovery in this

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case has not yet commenced, so Plaintiff’s counsel does not yet know whether this is going to

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trigger the need for additional discovery and possibly additional motion practice. Defendants’

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counsel believes these additional 30 days are sufficient to complete discovery.
Based on the foregoing circumstances, the parties respectfully stipulate to and request

Stipulation & [Proposed] Order to Extend Discovery Deadline: Case No. 2:15-cv-02513-WBS-AC

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an Order from the Court for the following:
1.

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That the deadline for the completion of all discovery be extended by 30-days,
from January 10, 2017, to February 9, 2017; and,

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2.

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That all other dates and deadlines remain as set for the time being.

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Respectfully submitted,

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Dated: December 9, 2016

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LAW OFFICE OF SANJAY S. SCHMIDT
By:

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Dated: December 9, 2016

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ALLEN, GLAESSNER,
HAZELWOOD & WERTH, LLP
By:

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/s/ Sanjay S. Schmidt
SANJAY S. SCHMIDT
Attorneys for Plaintiff
JOANNE BLIGHT

/s/ Kevin P. Allen1
DALE L. ALLEN, JR.
KEVIN P. ALLEN
Attorneys for Defendants
CITY OF MANTECA, ARMANDO
GARCIA, RANCH JOHNSON, KIRK
DOTY, MIKE KEENER, IAN OSBORN,
ARMEN AVAKIAN, PAUL CARMONA
and CHRIS S. MRAZ

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PURSUANT TO THE FOREGOING STIPULATION, AND ¶ IX OF THE STATUS
(PRETRIAL SCHEDULING) ORDER (ECF # 8), IT IS SO ORDERED.

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DATED: December 12, 2016

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Pursuant to Local Rule 131(e), counsel has authorized the submission of this document on
counsel’s behalf.
Stipulation & [Proposed] Order to Extend Discovery Deadline: Case No. 2:15-cv-02513-WBS-AC

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