Opinion
2:18-cv-02978-MCE-JDP
07-21-2021
BROOKS BRIDGES and ANITA STENGEL, Plaintiff, v. COUNTY OF SACRAMENTO, DAWN WALKER, JENNIFER LAMB, SACRAMENTO SHERIFF'S DEPARTMENT OFFICER MA, and DOES 1 through 50, inclusive, Defendants.
PORTER SCOTT A PROFESSIONAL CORPORATION Carl L. Fessenden Joceline M. Herman Attorneys for Defendants WEINBERGER LAW FIRM, PC. Joseph Weinberger Attorney for Plaintiffs
Complaint Filed: 11/14/2018
PORTER SCOTT A PROFESSIONAL CORPORATION Carl L. Fessenden Joceline M. Herman Attorneys for Defendants
WEINBERGER LAW FIRM, PC. Joseph Weinberger Attorney for Plaintiffs
JOINT STIPULATION TO MODIFY PRE-TRIAL SCHEDULING ORDER; ORDER THEREON
MORRISON C. ENGLAND JR., SENIOR UNITED STATES DISTRICT JUDGE
This Stipulation is entered into by and between Plaintiffs BROOKS BRIDGES and ANITA STENGEL (“Plaintiffs”) and COUNTY OF SACRAMENTO, DAWN WALKER, JENNIFER LAMB, SACRAMENTO SHERIFF'S DEPARTMENT OFFICER MA (“Defendants”) (“The Parties”). The Parties enter into the stipulation and proposed order in compliance with the Federal Rule of Civil Procedure 16(b) and the requirements of the scheduling order. The Parties have conferred and agree to request to continue the following:
• That the discovery cut-off date, which was set for January 15, 2021, be moved to August 20, 2021;
• That the expert witness disclosure cut-off date, which was set for March 12, 2021, be moved to October 22, 2021;
• That the supplemental expert witness disclosure cut-off date, which was set for April 12, 2021, be moved to November 24, 2021;
• That the Dispositive Motion filing cut-off date currently set for July 12, 2021, be move to February 25, 2022;
The Parties have good cause to request an extension. This calendaring modification is requested in light of the extensive COVID 19 pandemic closures (delaying certain matters in this case by over six months) and so that the parties can attempt to resolve the case prior to the completion of discovery and the retention or further retention of experts. There were significant delays in discovery as a result of the California Welfare and Institutions Code § 827 petition for release of the juvenile case records, as well as the court closures and shelter in place orders relating to the COVID 19 pandemic. Defendant has been unable to complete all the necessary depositions. The Parties need to complete discovery to be able to fully evaluate any and all settlement opportunities. The Parties believe that the savings in costs and attorney fees that this stipulation would permit could significantly increase the chances of resolution. Finally, is settlement is unsuccessful, Defendants intend to file a summary judgment motion in this matter, but the Parties need to complete discovery of Plaintiffs (which has been delayed due to the pandemic) prior to being able to file any such motion.
Therefore, the Parties request a continuance of all deadlines as detailed above so that Defendant may have the opportunity to defend this matter against Plaintiffs' claims.
IT IS SO STIPULATED.
IT IS SO ORDERED.