Velez v. City of Sacramento, et al

Filing 17

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 10/9/2019 EXTENDING the Fact Discovery Cut-Off to 3/16/2020 and Expert Witness Designation to 5/15/2020. (Huang, H)

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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, JOHN HARSHBARGER AND DANIEL
FARNSWORTH

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KRISTOPHER VELEZ,

Case No.: 2:18-cv-01914-MCE-CKD

Plaintiff,

STIPULATION AND ORDER TO
EXTEND DISCOVERY CUT-OFF

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vs.

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CITY OF SACRAMENTO; JOHN
HARSHBARGER; BAIL HOTLINE BAIL
BONDS, INC.; AMERICAN SURETY
COMPANY; and DOES 1 through 25,
inclusive,

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Defendants.

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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. In addition, Plaintiff may undergo further medical

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treatment that may have bearing on discovery and how the parties proceed with the case.

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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:

March 16, 2020

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EXPERT WITNESS DESIGNATION:

May 15, 2020

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DATED: October 7, 2019

SUSANA ALCALA WOOD,
City Attorney

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By:

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/s/ SEAN D. RICHMOND
SEAN D. RICHMOND
Senior Deputy City Attorney
Attorneys for the CITY OF
SACRAMENTO, JOHN HARSHBARGER,
AND DANIEL FARNSWORTH

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DATED: _________________, 2019

LAW OFFICE OF STEWART KATZ

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By:

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/s/ STEWART KATZ
STEWART KATZ
Attorneys for Plaintiff, KRISTOPHER VELEZ

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DATED: _________________, 2019

LEWIS BRISBOIS BISGAARD & SMITH LLP

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By:

/s/ ANDREW BLUTH
ANDREW BLUTH
Attorneys for BAIL HOTLINE BAIL BONDS,
INC., AMERICAN SURETY COMPANY

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I, Sean D. Richmond, certify that I have permission to affix the signatures of Stewart
Katz and Andrew Bluth to this document by email permission.

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STIPULATION AND ORDER TO EXTEND DISCOVERY CUT-OFF

ORDER

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Based on the stipulation of the parties to this action, and good cause appearing therefore,
IT IS HEREBY ORDERED that:
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Fact Discovery Cut-Off be extended to March 16, 2020; and

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Expert Witness Designation be extended to May 15, 2020.

IT IS SO ORDERED.
Dated: October 9, 2019

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STIPULATION AND ORDER TO EXTEND DISCOVERY CUT-OFF