Wroth et al v. City of Rohnert Park et al

Filing 61

STIPULATION AND ORDER re 60 STIPULATION WITH PROPOSED ORDER to Extend Disc. Deadlines filed by David Sittig-Wattson, City of Rohnert Park, Christopher Wroth, Eric Matzen, Matt Huot, Marni Wroth, Sean Huot, Mike Werle. Supplemental Expert Designation 2/11/2019. Expert Discovery Cut-Off and the Last Day to File Dispositive Motions 3/1/2019. Signed by Judge Jon S. Tigar on December 21, 2018. (wsn, COURT STAFF) (Filed on 12/21/2018)

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RAYMOND J. FULLERTON, ESQ., SBN 219264
MAGDALENA R. MCQUILLA, ESQ., SBN 307578
GEARY, SHEA, O’DONNELL, GRATTAN & MITCHELL, P.C.
90 South E Street, Suite 300
Santa Rosa, California 95404
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
CITY OF ROHNERT PARK,
DAVID SITTIG-WATTSON and SEAN HUOT

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CHRISTOPHER WROTH and MARNI
WROTH,

CASE NO.: 17-cv-05339-JST
PLAINTIFFS’ AND DEFENDANTS’
STIPULATION TO EXTEND DISCOVERY
DEADLINES; ORDER THEREON

Plaintiffs,
v.
CITY OF ROHNERT PARK, DAVID SITTIGWATTSON, SEAN HUOT, MATT HUOT,
MIKE WERLE, ERIC MATZEN and DOES 125,
Defendants.

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Pursuant to Northern District Local Rule 6-1, and the Court’s order of December 7, 2018

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(Doc. #58), plaintiffs CHRISTOPHER WROTH and MARNI WROTH and defendants CITY OF

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ROHNERT PARK, DAVID SITTIG-WATTSON, and SEAN HUOT, through their respective

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counsel, agree and stipulate as follows:

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1.

Plaintiffs CHRISTOPHER WROTH and MARNI WROTH filed their Complaint on

September 14, 2017, and filed a First Amended Complaint on June 19, 2018.
2.

On November 7, 2018, plaintiffs filed a motion for leave to file a Second Amended

LAW OFFICES OF

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GEARY,
SHEA,
O’DONNELL,27
GRATTAN &
MITCHELL
P.C.

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Complaint. The motion was granted on December 7, 2018.
3.

In its order, the Court granted the motion to amend in part on the grounds that

defendants would not suffer undue prejudice because delays in the case schedule would not be
________________________________________________________________________________
-1Stipulation to Extend Discovery Deadlines

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substantial and plaintiffs had agreed to stipulate to reopen fact discovery. (Doc. 58, pp. 4:23-5:5.)

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The Court directed the parties to meet and confer regarding any proposed amendments to the

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deadlines contained in the scheduling order and to then submit a joint stipulation for a new schedule

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containing “all proposed amended deadlines and a plan for additional discovery.” (Doc. 58, p.6:5-8.)
4.

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Pursuant to their meet and confer efforts, the parties hereby stipulate to extend the

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discovery deadlines as follows:

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A.

Defendants will serve additional written discovery by email on or before

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December 21, 2018. Plaintiffs will respond to that discovery by email on or before January 10,

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2019.

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B.

Supplemental Expert Designation will be extended to February 11, 2019.

Defendants will serve a Rule 26 report on the newly-added issues on that date.
C.

Expert Discovery Cut-Off and the Last Day to File Dispositive Motions will

be extended to March 1, 2019.
D.

All other deadlines in the Court’s April 19, 2018 Scheduling Order (Doc. 35)

remain unchanged.

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IT IS SO STIPULATED.

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Dated: December 19, 2018

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SCOTT LAW FIRM / IZAAK D. SCHWAIGER
By

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_____/s/ Izaak D. Schwaiger____________________
IZAAK D. SCHWAIGER
Attorneys for Plaintiffs
CHRISTOPHER WROTH and MARNI WROTH

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Dated: December 19, 2018

GEARY, SHEA, O’DONNELL, GRATTAN &
MITCHELL, P.C.

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LAW OFFICES OF

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GEARY,
SHEA,
O’DONNELL,27
GRATTAN &
MITCHELL
P.C.

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By

/s/ Raymond J. Fullerton
RAYMOND J. FULLERTON
Attorneys for Defendants
CITY OF ROHNERT PARK,
DAVID SITTIG-WATTSON, SEAN HUOT, MATT

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-2Stipulation to Extend Discovery Deadlines

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CIVIL LOCAL RULE 5-1(i)(3) ATTESTATION
I hereby attest that concurrence in the filing of this document has been obtained from each
of the other signatories to this document.

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Dated: December 19, 2018

GEARY, SHEA, O’DONNELL, GRATTAN &
MITCHELL, P.C.

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By

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/s/ Raymond J. Fullerton
RAYMOND J. FULLERTON
Attorneys for Defendants
CITY OF ROHNERT PARK,
DAVID SITTIG-WATTSON, SEAN HUOT, MATT
HUOT, MIKE WERLE and ERIC MATZEN

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PURSUANT TO STIPULATION, IT IS SO ORDERED

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Date: December 21, 2018

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____________________________________
United States District Court Judge

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LAW OFFICES OF

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GEARY,
SHEA,
O’DONNELL,27
GRATTAN &
MITCHELL
P.C.

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-3Stipulation to Extend Discovery Deadlines