Johnson v. City of Sacramento Police Department et al

Filing 10

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 4/3/2019 ORDERING: Fact Discovery cutoff is 7/15/2019; Expert Discovery Cutoff is 9/15/2019. (Washington, S)

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SUSANA ALCALA WOOD, City Attorney (SBN 156366)
SEAN D. RICHMOND, Senior Deputy City Attorney (SBN 210138)
[e-mail]
CITY OF SACRAMENTO
915 I Street, Room 4010
Sacramento, CA 95814-2608
Telephone: [phone]
Telecopier: [phone]
Attorneys for the CITY OF SACRAMENTO POLICE DEPARTMENT and POLICE
OFFICER PATRICK MULLIGAN

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CANDIDA JOHNSON,

Case No.: 2:18-cv-00639-MCE-KJN

Plaintiff,

STIPULATION AND ORDER TO
EXTEND DISCOVERY CUT-OFF

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vs.

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CITY OF SACRAMENTO POLICE
DEPARTMENT; POLICE OFFICER
PATRICK MULLIGAN; and DOES 1
through 25, inclusive,
Defendants.

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TO: THE HONORABLE MAGISTRATE JUDGE KENDALL J. NEWMAN
IT IS HEREBY STIPULATED between the parties, by and through their respective

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counsel of record that the discovery cut-off be extended.

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The parties are in the process of meeting and conferring on discovery issues and need

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additional time to complete discovery and have only recently discovered the identity of

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potentially relevant witnesses that were disclosed in Supplemental Rule 26 Disclosures.
The parties further stipulate and agree that any additional discovery will be related to

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depositions only and not to additional written discovery.

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STIPULATION AND ORDER TO EXTEND DISCOVERY CUT-OFF

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It is stipulated between the parties, that the following cutoff dates be set:

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FACT DISCOVERY CUT-OFF:

07-15-2019

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EXPERT DISCOVERY CUTOFF:

09-15-2019

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DATED: April 2, 2019

LAW OFFICES OF JOSE R. VALDEZ

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By:

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/s/ JOSE R. VALDEZ
JOSE R. VALDEZ
Attorneys for Plaintiff, CANDIDA
JOHNSON

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DATED: April 2, 2019

KRAVITZ LAW OFFICE

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By:

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/s/ JEFFREY S. KRAVITS
JEFFREY S. KRAVITZ
Attorneys for Plaintiff, CANDIDA
JOHNSON

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DATED: April 2, 2019

SUSANA ALCALA WOOD
City Attorney

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By:

/s/ SEAN D. RICHMOND
SEAN D. RICHMOND
Senior Deputy City Attorney
Attorneys for the CITY OF SACRAMENTO
POLICE DEPARTMENT and POLICE
OFFICER PATRICK MULLIGAN

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I, Sean D. Richmond, certify that I have permission to affix the signatures of Jeffrey S.
Kravitz and Jose R. Valdez to this document by email permission.

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STIPULATION AND ORDER TO EXTEND DISCOVERY CUT-OFF

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ORDER

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Good cause appearing, IT IS SO ORDERED.

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Dated: April 3, 2019

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STIPULATION AND ORDER TO EXTEND DISCOVERY CUT-OFF