G.I.S.E. et al v. City of Chico et al

Filing 29

ORDER signed by Magistrate Judge Jeremy D. Peterson on 9/24/ CONTINUING the deadlines and RESETTING as follows: Discovery due by 12/20/2024, Dispositive Motions due by 2/27/2025, Motion to Compel due by 1/23/2025. (Kyono, V)

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Roger A. Colvin, Esq. (SBN 68773)
Sharon Medellín (SBN 213798)
ALVAREZ-GLASMAN & COLVIN
Attorneys at Law
13181 Crossroads Parkway North, Suite 400
City of Industry, CA 91746
Tel. [phone] · Fax [phone]
[e-mail] [e-mail]
Attorneys for Defendants City of Chico,
Officer Mark Bass, and Officer David Bailey

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Fulvio F. Cajina (SBN 289126)
LAW OFFICES OF FULVIO F. CAJINA
528 Grand Avenue
Oakland, CA 94610
Tel: [phone]/Fax: [phone]
Email: [e-mail]
Stanley Goff (SBN 289564)
Law Office Of Stanley Goff
15 Boardman Place, Suite 2
San Francisco, CA 94103
Telephone: [phone]
Email: [e-mail]
Attorneys for Plaintiff G.I.S.E.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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G. I. S. E. by and through his guardian ad
litem, EDDIE SANCHEZ,
Plaintiff,
vs.
CITY OF CHICO, CHICO POLICE
DEPARTMENT, MARK BASS, DAVID
BAILEY, and DOES 1-50,

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Case No.: 2:22-cv-01654-JDP

STIPULATION TO CONTINUE SCHEDULING
DEADLINES AND ORDER

Defendants.

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STIPULATION AND PROPOSED
ORDER

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STIPULATION

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Plaintiff G.I.S.E., by and through his guardian ad litem, EDDIE SANCHEZ, and Defendants

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CITY OF CHICO, CHICO POLICE DEPARTMENT, MARK BASS, and DAVID BAILEY (the

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“Chico Defendants”), by and through their respective counsel of record in the above-captioned

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litigation, hereby stipulate and request that the Court enter an order to continue certain case

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management deadlines.
WHEREAS, the parties were expecting to complete discovery in October 2024 by, among

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other things, completing the depositions of certain percipient witnesses in Chico, California;
WHEREAS, counsel for the Chico Defendants is scheduled to commence trial in the United

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States District Court for the Eastern District of California on October 7, 2024, in the case of the
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Estate of Tyler S. Rushing, et al. v. AG Private Protection, Inc., et al. (U.S.D.C. Case No. 2:18-cv01692-DAD-AC);

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WHEREAS, counsel for the Chico Defendants does not have sufficient time to complete
discovery in this matter by the current deadline of October 11, 2024, due to that federal trial; and

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WHEREAS, counsel for both sides believe it makes sense to postpone discovery cutoff and
related pre-trial dates in this matter due to defense counsel’s trial schedule.

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NOW, THEREFORE, the parties respectfully request this Court extend the deadlines in this
matter as follows:

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Event

Current Deadline

Proposed Deadline

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Discovery Cutoff

October 11, 2024

December 20, 2024

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Motion to Compel Discovery
Deadline

November 15, 2024

January 24, 2025

Last day to hear dispositive
motion

December 18, 2024

February 28, 2025

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Good cause exists for continuance of deadlines reflected above as required pursuant to

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Federal Rule of Civil Procedure Rule 16(b)(4) due to defense counsel’s trial schedule, which has

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significantly impacted the parties’ ability to complete discovery.

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STIPULATION AND PROPOSED ORDER

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This is the parties’ fourth request for continuance of case management deadlines. The
parties do not currently foresee the need for a further continuance in the future.

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IT IS SO STIPULATED.
Dated: September 20, 2024

LAW OFFICE OF FULVIO F. CAJINA

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By: _

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/s/ Fulvio Cajina
FULVIO F. CAJINA
Attorneys for Plaintiff
G.I.S.E.

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Dated: September 20, 2024

ALVAREZ-GLASMAN & COLVIN

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By: _
Sharon Medellín
Attorneys for Defendants
CITY OF CHICO, et al.

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STIPULATION AND PROPOSED ORDER

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PROPOSED ORDER
GOOD CAUSE APPEARING, the parties’ stipulation is GRANTED, as modified below.

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The following deadlines are CONTINUED and RESET as follows:
Event

Current Deadline

Proposed Deadline

Discovery Cutoff

October 11, 2024

December 20, 2024

Motion to Compel Discovery
Deadline

November 15, 2024

January 23, 2025

Last day to hear dispositive
motion

December 18, 2024

February 27, 2025

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IT IS SO ORDERED.
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Dated:

September 24, 2024
JEREMY D. PETERSON
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND PROPOSED ORDER