Rush et al v. City of Fairfield et al

Filing 22

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 1/13/2023 EXTENDING the Deadlines: Designation of Expert Witnesses due by 5/1/2023; Discovery due by 6/5/2023; and Motions shall be filed by 6/20/2023. (Donati, J)

Case 2:21-cv-01120-WBS-KJN Document 22 Filed 01/17/23 Page 1 of 4
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PATRICK MORIARTY, State Bar No. 213185
[e-mail]
JOHN B. ROBINSON, State Bar No. 297065
[e-mail]
JOANNE TRAN, State Bar No. 294402
[e-mail]
CASTILLO, MORIARTY, TRAN & ROBINSON
75 Southgate Avenue
Daly City, CA 94015
Telephone:
[phone]

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75 Southgate Avenue
Daly City, California 94015

CASTILLO, MORIARTY, TRAN & ROBINSON, LLP

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Attorneys for Defendants
CITY OF FAIRFIELD AND ZACHARY SANDOVAL

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CALVIN RUSH and JAYME RUSH,

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Plaintiff,

Case No. 2:21-cv-01120-WBS-KJN
STIPULATION AND ORDER TO EXTEND
DISCOVERY DEADLINES

v.
Hon. William B. Shubb

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CITY OF FAIRFIELD, OFFICERS
ZACHARY SANDOVAL AND DUSTIN
JOSEPH,
Defendants.

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IT IS HEREBY STIPULATED, and respectfully requested, by and between Plaintiffs and
Defendants by and through their designated counsel, that:

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WHEREAS, on June 21, 2021, Plaintiffs filed their Complaint. (Doc. 1).

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WHEREAS, on February 2, 2022, Defendants City of Fairfield and Zachary Sandoval filed

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their Answer. (Doc. 10).

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WHEREAS, on March 16, 2022, the Court issued the case schedule (Doc. 12);

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WHEREAS, the current discovery schedule is set as:

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Designation of Expert Witnesses due by 2/7/2023
Discovery shall be completed by 4/11/2023
Motions shall be filed by 6/20/2023
Final Pretrial Conference set for 8/28/2023 at 01:30 PM
Jury Trial set for 10/31/2023

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1

STIP TO EXTEND DISCOVERY
2:21-CV-01120-WBS-KJN

Case 2:21-cv-01120-WBS-KJN Document 22 Filed 01/17/23 Page 2 of 4
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WHEREAS, Defendants City of Fairfield and Zachary Sandoval retained new counsel in
January 2023;

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WHEREAS, expert disclosures are due on February 7, 2023;

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WHEREAS, discovery shall be completed by April 11, 2023;

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WHEREAS, newly retained counsel for the City of Fairfield and Zachary Sandoval requires

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additional time to review the case and conduct its own discovery;

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WHEREAS, the parties met and conferred and agreed to extend discovery dates and set
case schedule as proposed below:

75 Southgate Avenue
Daly City, California 94015

CASTILLO, MORIARTY, TRAN & ROBINSON, LLP

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Designation of Expert Witnesses due by 5/1/2023
Discovery shall be completed by 6/5/2023
Motions shall be filed by 6/20/2023
Final Pretrial Conference set for 8/28/2023 at 01:30 PM
Jury Trial set for 10/31/2023

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IT IS SO AGREED.

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Respectfully submitted,
Dated: January 11, 2023

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CASTILLO, MORIARTY,
TRAN & ROBINSON, LLP
By:

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/s/ Patrick Moriarty
PATRICK MORIARTY
JOHN ROBINSON
JOANNE TRAN
Attorneys for Defendants
CITY OF FAIRFIELD and ZACHARY
SANDOVAL

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Dated: January 11, 2023

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BERTRAND FOX ELLIOT OSMAN & WENZEL
By:

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/s/ Richard Osman
RICHARD W. OSMAN
Attorneys for Defendants
DUSTIN JOSEPH

///
///

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STIP TO EXTEND DISCOVERY
2:21-CV-01120-WBS-KJN

Case 2:21-cv-01120-WBS-KJN Document 22 Filed 01/17/23 Page 3 of 4
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LAW OFFICE OF STANLEY GOFF
Dated: January 11, 2023
By:

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/s/Stanley Goff
STANLEY GOFF
Attorney for Plaintiffs
CALVIN RUSH and JAYME RUSH

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75 Southgate Avenue
Daly City, California 94015

CASTILLO, MORIARTY, TRAN & ROBINSON, LLP

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STIP TO EXTEND DISCOVERY
2:21-CV-01120-WBS-KJN

Case 2:21-cv-01120-WBS-KJN Document 22 Filed 01/17/23 Page 4 of 4
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ORDER
IT IS SO ORDERED:

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The dates are reset as follows:

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75 Southgate Avenue
Daly City, California 94015

CASTILLO, MORIARTY, TRAN & ROBINSON, LLP

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Designation of Expert Witnesses due by 5/1/2023
Discovery shall be completed by 6/5/2023
Motions shall be filed by 6/20/2023
Final Pretrial Conference set for 8/28/2023 at 1:30 PM (unchanged)
Jury Trial set for 10/31/2023 at 9:00AM (unchanged)

Dated: January 13, 2023

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STIP TO EXTEND DISCOVERY
2:21-CV-01120-WBS-KJN