Sessoms v. Keller et al

Filing 32

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 2/21/19 CONTINUING the deadline to propound discovery to 4/25/19, discovery cut-off is continued to 4/25/19, deadline to file motion to amend the complaint is continued to 6/27/19 and deadline to file dispositive motions is continued to 9/26/2019. (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.: 2:17-cv-00304-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,
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Complaint Filed:
FAC Filed:

February 14, 2017
August 8, 2017

Defendant.

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

17 KELLER (“Defendant”), through their respective undersigned counsel, hereby respectfully submit
18 the following Joint Stipulation and [Proposed] Order to Modify the Court’s October 30, 2018,
19 AMENDED DISCOVERY AND SCHEDULING ORDER.
STIPULATION

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WHEREAS, the Court issued a Discovery and Scheduling Order on September 27, 2018,

22 filed September 28, 2018 (ECF Doc No. 24), as modified by the Court’s subsequent October 30,
23 2018, filed October 31, 2018 (ECF Doc No. 27).
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WHEREAS, the Court’s Amended Discovery and Scheduling Order, dated October 30,

25 2018, requires the parties to complete discovery investigation by March 15, 2019.
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WHEREAS, Plaintiff’s counsel, Dominick R. Welch, entered as attorney of record on

27 January 31, 2019.
28 ///
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JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY DISCOVERY AND SCHEDULING
ORDER (CASE NO.: 2:17-CV-00304-WBS-EFB)

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WHEREAS, the current Discovery and Scheduling Order does not allow the parties time

2 to complete discovery. Furthermore, the parties are continuing to meet and confer regarding
3 responses to written discovery from Defendants’ Special Interrogatories and Request for
4 Production of Documents, which includes five separate document requests.
5

WHEREAS, the parties agree that good cause exists to extend all remaining deadlines in

6 the Court’s Amended Discovery and Scheduling Order, dated October 30, 2018 (ECF Doc No.
7 27), as follows:
8

10

EVENT

CURRENT DATE

Discovery Requests Deadline

January 11, 2019
April 25, 2019
[Discovery and Scheduling
Order (“D&SO”), ECF Doc
No. 27, pp. 4:15.]

Discovery Cut-Off Deadline

9

March 15, 2019
June 27, 2019
(D&SO, ECF Doc No. 27, pp.
4:13.)

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

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NEW DATE

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Deadline to File Motion to March 15, 2019
June 27, 2019
Amend Complaint
(D&SO, ECF Doc No. 27, pp.
4:17.)

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17

Deadline to File Dispositive June 14, 2019
September 26, 2019
Motions
(D&SO, ECF Doc No. 27, pp.
4:18.)

18
19 Dated: February 13, 2019

WELCH LAW FIRM

20

22

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

23 Dated: February 13, 2019

CITY OF SACRAMENTO

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/s/ Andrea M. Velasquez
Andrea M. Velasquez
Attorney for Defendant,
JOHN PATRICK KELLER

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JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY DISCOVERY AND SCHEDULING
ORDER (CASE NO.: 2:17-CV-00304-WBS-EFB)

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2

[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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5

1.

Continue the deadline to propound discovery from January 11, 2019, to

April 25, 2019;

6

2.

Continue the discovery cut-off from March 15, 2019, to June 27, 2019;

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3.

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

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15, 2019, to June 27, 2019; and
4.

Continue the deadline to file Dispositive Motions from June 14, 2019, to

September 26, 2019.

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

11 IT IS SO ORDERED.
12
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.: 2:17-CV-00304-WBS-EFB)