Sessoms v. Keller et al

Filing 71

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 2/21/19 CONTINUING the deadline to propound discovery to 4/19/2019, discovery cut-off is continued to 6/21/2019, the deadline to file motion to amend the complaint is continued to 6/21/2019 and the deadline to file dispositive motions is continued to 9/20/2019. (Kastilahn, A)

1 Dominick R. Welch (SBN 311096)
WELCH LAW FIRM
2 300 Harding Boulevard, Suite 109
Roseville, CA 95678
3 Telephone: [phone]
Facsimile: [phone]
4 [e-mail]
5 Attorney for Plaintiff,
TIO DINERO SESSOMS
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
Case No.: 2:16-cv-01943-WBS-EFB

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WELCH LAW FIRM
300 Harding Boulevard, Suite 109
Roseville, CA 95678

10 TIO DINERO SESSOMS,

JOINT STIPULATION AND [PROPOSED]
ORDER TO MODIFY DISCOVERY AND
SCHEDULING ORDER

Plaintiff,

12 v.
13 JOHN PATRICK KELLER, et al.,
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Complaint Filed:
FAC Filed:

August 18, 2016
June 20, 2017

Defendants.

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Plaintiff, TIO DINERO SESSOMS (“Plaintiff”) and Defendants JOHN PATRICK

17 KELLER and DICK WOODS (“Defendants”), through their respective undersigned counsel,
18 hereby respectfully submit the following Joint Stipulation and [Proposed] Order to Modify the
19 Court’s October 10, 2018, DISCOVERY AND SCHEDULING ORDER.
STIPULATION

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WHEREAS, the Court issued a Discovery and Scheduling Order on October 9, 2018, and

22 filed October 10, 2018. (ECF Doc No. 59.)
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WHEREAS, the Court’s Discovery and Scheduling Order, dated October 9, 2018, requires

24 the parties to complete discovery investigation by February 15, 2019.
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WHEREAS, Plaintiff’s counsel, Dominick R. Welch, entered as attorney of record on

26 January 31, 2019.
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WHEREAS, the current Discovery and Scheduling Order does not allow the parties time

28 to complete discovery. Furthermore, the parties are continuing to meet and confer regarding
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JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY DISCOVERY AND SCHEDULING
ORDER (CASE NO.: 2:16-CV-01943-WBS-EFB)

1 responses to written discovery from Defendants’ Special Interrogatories and Request for
2 Production of Documents, which includes seven separate document requests.
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WHEREAS, the parties agree that good cause exists to extend all remaining deadlines in

4 the Court’s Discovery and Scheduling Order, dated October 9, 2018 (ECF Doc No. 59), as follows:
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EVENT

CURRENT DATE

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Discovery Requests Deadline

December 14, 2018
April 19, 2019
[Discovery and Scheduling
Order (“D&SO”), ECF Doc
No. 59, pp. 4:13.]

Discovery Cut-Off Deadline

February 15, 2019
June 21, 2019
(D&SO, ECF Doc No. 59, pp.
4:15.)

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NEW DATE

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WELCH LAW FIRM
300 Harding Boulevard, Suite 109
Roseville, CA 95678

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Deadline to File Motion to February 15, 2019
June 21, 2019
Amend Complaint
(D&SO, ECF Doc No. 59, pp.
4:17.)

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Deadline to File Dispositive May 17, 2019
September 20, 2019
Motions
(D&SO, ECF Doc No. 59, pp.
4:18.)

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Dated: February 13, 2019

WELCH LAW FIRM

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/s/ Dominick R. Welch
Dominick R. Welch
Attorney for Plaintiff,
TIO DINERO SESSOMS

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Dated: February 13, 2019

CITY OF SACRAMENTO

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/s/ Andrea M. Velasquez
Andrea M. Velasquez
Attorney for Defendants,
JOHN PATRICK KELLER and DICK
WOODS

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------------JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY DISCOVERY AND SCHEDULING
ORDER (CASE NO.: 2:16-CV-01943-WBS-EFB)

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[PROPOSED] ORDER
The Court, having reviewed the JOINT STIPULATION TO MODIFY DISCOVERY

3 AND SCHEDULING ORDER and finding good cause, issues an Order to:
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1.

Continue the deadline to propound discovery from December 14, 2018, to

April 19, 2019;

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2.

Continue the discovery cut-off from February 15, 2019, to June 21, 2019;

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3.

Continue the deadline to file a Motion to Amend the Complaint from

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February 15, 2019, to June 21, 2019; and
4.

Continue the deadline to file Dispositive Motions from May 17, 2019, to

September 20, 2019.

WELCH LAW FIRM
300 Harding Boulevard, Suite 109
Roseville, CA 95678

11 IT IS SO ORDERED.
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13 Dated: February 21, 2019
14

EDMUND F. BRENNAN
U.S. MAGISTRATE JUDGE

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------------JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY DISCOVERY AND SCHEDULING
ORDER (CASE NO.: 2:16-CV-01943-WBS-EFB)