Bonilla-Chirinos, et al. v. City of West Sacramento, et al.

Filing 29

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 4/17/17: The discovery cutoff date of April 21, 2017, is hereby extended for the limited purpose of allowing for the completion of the depositions of Guillermo Bonilla- Chirinos and Sandra Hernandez. Therefore, the depositions previously noticed for April 17 and 18, 2017, are hereby ordered reset for April 27 and 28, 2017, respectively. (Kaminski, H)

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CYRUS ZAL, SBN: 102415
CYRUS ZAL, A PROFESSIONAL CORPORATION
102 Mainsail Court
Folsom, CA 95630
[phone]
[phone] (FAX)
Email: [e-mail]
Attorney for Plaintiffs GUILLERMO BONILLA, SANDRA HERNANDEZ AND J.B., A
MINOR

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AMIE McTAVISH (SB No. 242371)
Email: [e-mail]
SEAN D. O’DOWD (SB No. 296320)
Email: [e-mail]
ANGELO, KILDAY&KILDUFF, LLP
Attorneys at Law
601 University Avenue, Suite 150
Sacramento, CA95825
Telephone: [phone]
Telecopier: [phone]

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Attorneys for Defendants CITY OF WEST SACRAMENTO and KENNETH FELLOWS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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)
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Plaintiffs,
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vs.
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CITY OF WEST SACRAMENTO,
KENNETH FELLOWS (BADGE #151) AND )
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DOES 1 THROUGH 99,
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Defendants.
______________________________________ )
GUILLERMO BONILLA-CHIRINOS,
SANDRA HERNANDEZ, INDIVIDUALLY
AND AS GUARDIANS AD LITEM OF J B,
A MINOR

Case No.: 2:15-cv-02564-WBS-EFB

STIPULATION AND [PROPOSED]
ORDER MODIFYING THE PRETRIAL
SCHEDULING ORDER TO TAKE TWO
DEPOSITIONS BEYOND THE
DISCOVERY CUT-OFF DATE

-1STIPULATION AND [PROPOSED] ORDER MODIFYING THE PRETRIAL SCHEDULING
ORDER, etc.

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COMES NOW THE PARTIES by and through their respective counsel and subject to the
approval of this Court, hereby stipulate and respectfully request the following modification to
this Court’s Pretrial Scheduling Order of November 17, 2016 (Court’s Docket No. 25): that the
depositions of Plaintiffs Guillermo Bonilla-Chirinos and Sandra Hernandez be taken by
Defendants beyond the current discovery cut-off date of April 21, 2017.
There is good cause for this modification as follows:

the depositions of Plaintiffs

Guillermo Bonilla-Chirinos and Sandra Hernandez were originally scheduled before the
discovery cut-off date of April 21, 2017. Plaintiff Sandra Hernandez’s deposition was originally
scheduled on April 17, 2017 and Plaintiff Guillermo Bonilla-Chirinos’ deposition was originally
scheduled on April 18, 2017. However, those dates became unavailable to said Plaintiffs due to
employment matters and other matters, and Plaintiffs requested that their depositions be rescheduled to April 27, 2017 (Plaintiff Guillermo Bonilla-Chirinos) and to April 28, 2017
(Plaintiff Sandra Hernandez). Defendants agreed to the new dates subject to the Court’s approval
of Plaintiffs’ depositions being taken beyond the discovery cut-off date of April 21, 2017.
The parties therefore have respectfully submitted this Stipulation and Order requesting
the Court to approve Plaintiffs’ depositions being taken beyond the discovery cut-off date of
April 21, 2017.
Dated: April 17, 2017

ANGELO, KILDAY&KILDUFF, LLP

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/s/ Sean D. O’Dowd
By:_________________________________
AMIE McTAVISH
SEAN D. O’DOWD
Attorneys for Defendants

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Dated: April 13, 2017

CYRUS ZAL, A PROFESSIONAL
CORPORATION

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By:_____/s/ Cyrus Zal_________________
CYRUS ZAL
Attorney for Plaintiffs
-2STIPULATION AND [PROPOSED] ORDER MODIFYING THE PRETRIAL SCHEDULING
ORDER, etc.

ORDER

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Good cause appearing, the parties’ stipulation is approved as modified herein.
Accordingly, it is ordered that the discovery cutoff date of April 21, 2017, is hereby extended for
the limited purpose of allowing for the completion of the depositions of Guillermo BonillaChirinos and Sandra Hernandez. Therefore, the depositions previously noticed for April 17 and
18, 2017, are hereby ordered reset for April 27 and 28, 2017, respectively.

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IT IS SO ORDERED.
Dated: April 17, 2017.

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-3STIPULATION AND [PROPOSED] ORDER MODIFYING THE PRETRIAL SCHEDULING
ORDER, etc.