Thomas v. City of Folsom

Filing 14

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 12/16/2016 ORDERING that the Initial Scheduling Conference is CONTINUED to 2/13/2017 at 01:30 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb; the parties' Joint Status Report is due on or before 1/30/2017; and the parties shall meet and confer on a discovery plan as required by FRCP 26(f) on or before 1/17/2017. (Jackson, T)

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David E. Mastagni, Bar No. 204244
Isaac S. Stevens, Bar No. 251245
Ace T. Tate, Bar No. 262015
MASTAGNI HOLSTEDT
A Professional Corporation
1912 "I" Street
Sacramento, California 95811
Telephone:[phone]
Facsimile: 916.447.4614

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Attorneys for Plaintiff

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CAROLEE G. KILDUFF, SBN 107232
Email: [e-mail]
ANGELO, KILDAY & KILDUFF, LLP
Attorneys at Law
601 University Avenue, Suite 150
Sacramento, CA 95825

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Telephone: [phone]
Telecopier: [phone]

Attorneys for Defendant CITY OF FOLSOM

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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BRIAN THOMAS, on behalf of himself and all )
similarly situated individuals,
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Plaintiff,
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vs.
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CITY OF FOLSOM,
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)
Defendants.
)
______________________________________ )

Case No.: 2:16-cv-02038-WBS
STIPULATION TO CONTINUE INITIAL
STATUS CONFERENCE AND RELATED
DATES; [PROPOSED] ORDER

Plaintiff BRIAN THOMAS (“Plaintiff”) and Defendant CITY OF FOLSOM
(“Defendant”), by and through their respective counsel, hereby stipulate as follows:
A.

WHEREAS, Plaintiff filed its complaint on August 25, 2016, and served

Defendant on November 17, 2016;
-1STIPULATION TO CONTINUE INITIAL STATUS CONFERENCE AND RELATED DATES

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B.

WHEREAS, the Court scheduled an initial status (pretrial scheduling) conference

for January 3, 2017, and the parties' Joint Status Report is due December 20, 2016.
C.

WHEREAS, the parties stipulated for an extension of time for Defendant to file a

response to the complaint, up to and including January 5, 2017.
D.

WHEREAS, Defendant will not have formally appeared in this case until after the

current deadline to file a Joint Status Report and the initial status conference has passed.
C.

WHEREAS, the parties request additional time to evaluate their respective claims

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and defenses in order to meaningfully participate in preparation of a joint status report and the

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initial status conference.

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NOW THEREFORE, Plaintiff and Defendant stipulate that:

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1.

It is in the interest of judicial economy to continue the initial status conference

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from January 3, 2017, to February 7, 2017. No party will be prejudiced by a continuance of the

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initial status conference.

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2.

The parties further stipulate that the Joint Status Report be due on or before

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January 24, 2017.

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3.

The parties agree to meet and confer on a discovery plan as required by FRCP

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26(f) on or before January 17, 2017.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: December 16, 2016

By:/s/ Carolee G. Kilduff
CAROLEE G. KILDUFF
Attorneys for Defendant
CITY OF FOLSOM

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ANGELO, KILDAY & KILDUFF, LLP

Dated: December 16, 2016

MASTAGNI HOLSTEDT, APC

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By: /s/ Ace T. Tate
DAVID E. MASTAGNI
ISAAC S. STEVENS
ACE T. TATE
Attorneys for Plaintiff
-2STIPULATION TO CONTINUE INITIAL STATUS CONFERENCE AND RELATED DATES

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ORDER

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PURSUANT TO STIPULATION BY THE PARTIES TO THIS CASE, IT IS HEREBY

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ORDERED THAT:

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1.

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1:30 p.m.

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2.

The parties’ Joint Status Report is due on or before January 30, 2017.

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3.

The parties shall meet and confer on a discovery plan as required by FRCP 26(f) on or

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before January 17, 2017.

The initial status conference is continued from January 3, 2017, to February 13, 2017 at

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Dated: December 16, 2016

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-3STIPULATION TO CONTINUE INITIAL STATUS CONFERENCE AND RELATED DATES