Opinion
LAW OFFICE OF STEWART KATZ, Stewart Katz, Sacramento, CA, LAW OFFICES OF DALE K. GALIPO, Dale K. Galipo, Thomas C. Seabaugh, Woodland Hills, CA, Attorneys for Plaintiff, ROBERT I. REESE, JR.
A PROFESSIONAL CORPORATION, John R. Whitefleet, Taylor W. Rhoan, Sacramento, California, Attorneys for Defendants COUNTY OF SACRAMENTO, SCOTT JONES, JOSEPH MILLICAN, ZACHARY ROSE, and DUNCAN BROWN.
STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER AND CONTINUE PRETRIAL CONFERENCE AND TRIAL DATE
JOHN A. MENDEZ, District Judge.
IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ROBERT REESE and Defendants COUNTY OF SACRAMENTO, ZACHARY ROSE, and DUNCAN BROWN, by and through their undersigned Counsel, pursuant to Local Rule 143 as follows:
1. The parties respectfully request that the District Court modify the Pretrial Scheduling Order to continue the Pretrial Conference to August 21, 2015 and continue the date of trial to October 26, 2015, based on good cause appearing as more fully set forth below.
2. The parties have previously modified discovery and expert disclosure deadlines on five prior occasions by Stipulation and Order on March 5, 2014 (Document 18), June 17, 2014 (Document 20), January 5, 2015 (Document 31), April 17, 2015 (Document 50) and on May 1, 2015 (Document 53). The other deadlines including the dates originally set for trial, pretrial conference and dispositive hearing, as well as the associated deadlines, was previously modified by the Scheduling Order on June 17, 2014 (Document 20.)
3. On July 22, 2015, the Court issued a Minute Order continuing the Pretrial Conference from August 7, 2015 to August 14, 2015, due to the Court's trial schedule. Counsel for Defendants has a conflict with the date of the Pretrial Conference currently set for August 14, 2015, due to a previously scheduled trial in Stanislaus County. The parties submit good cause exists to further modify the scheduling order to continue the date of the Pretrial Conference and Trial.
4. Therefore, the parties respectfully submit that good cause exists to amend the discovery deadlines of the Pretrial Scheduling Order dated June 17, 2014, as follows:
Deadline Old Date New Date Joint Pretrial Statement Due July 31, 2015 August 14, 2015 Pretrial Conference August 7, 2015 August 21, 2015 at 11:00 a.m. at 10:00 a.m. Trial September 14, 2015 October 26, 2015 at 9:00 a.m. at 9:00 a.m.
This Stipulation may be signed in counterparts and any facsimile or electronic signature shall be as valid as an original signature.
IT IS SO STIPULATED. ORDER
Having reviewed the above stipulation and good cause appearing therefore, IT IS HEREBY ORDERED that the Pretrial Scheduling Order, be modified with the new schedule as set forth above.
IT IS SO ORDERED.