|}poRTER | SCOTT 2 |] A PROFESSIONAL CORPORATION William E. Camy, SBN 291397 3 Megan N. Robertson, SBN 340235 4 350 University Avenue, Suite 200 Sacramento, California 95825 5 || TEL: 916.929.1481 FAX: 916.927.3706 6 || [email protected] [email protected] 7 Attorneys for Defendants 8 CITY OF GRIDLEY and ANTHONY LARA Exempt from filing fee pursuant to Government Code section 6103 9 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 MARCO ANTHONY GARCIA —PADILLA, — CASE NO: 2:21-cv-00206-TLN-DMC an individual 13 STIPULATION AND ORDER TO FURTHER 14 Plaintiff, MODIFY PRE-TRIAL SCHEDULING ORDER vs. 15 CITY OF GRIDLEY, a legal 16 || Subdivision of the State of California; ANTHONY LARA, an individual; and 17 || DOES 1 through 10, inclusive, 18 Defendants. / Complaint Filed: 02/03/2021 19 20 In accordance with Local Rule 144 and Federal Rule 6, Plaintiff MARCO ANTHONY □□□□□□ 21 ||/PADILLA (‘Plaintiff’) and Defendants CITY OF GRIDLEY and ANTHONY LARA (collectiv 22 ||“Defendants”), by and through their respective undersigned counsel, respectfully request that this Court er 23 || an Order extending future deadlines in the Modified Pretrial Scheduling Order (the “Scheduling Order”) < 24 |! the Order modifying the Scheduling Order (ECF 4; ECF 10). In support of the instant stipulated request, 25 || parties state as follows: 26 1. WHEREAS, the Court’s February 3, 2021 Initial Pretrial Scheduling Order (ECF 4) set a date 27 January 21, 2022 for the disclosure of expert discovery; 28 2. WHEREAS, the parties have engaged in settlement discussions;

□ STIPULATION AND ORDER TO FURTHER MODIFY PRE-TRIAL SCHEDULING ORDER

1 3. WHEREAS, the parties requested, and the Court entered, an Order (ECF 10) extending the 2 deadline to disclose expert witnesses to February 18, 2022 and the deadline to disclose 3 supplemental / rebuttal expert witnesses to March 22, 2022; 4 4. WHEREAS, the parties have scheduled a Settlement Conference with Magistrate Judge Grosjean 5 on March 7, 2022 (ECF 12); 6 5. WHEREAS, the parties stipulate it would be most efficient and productive to continue the 7 deadlines to disclose expert witnesses, conduct expert discovery, and file any dispositive 8 motion(s) so the parties do not potentially unnecessarily incur the cost and fees of such activities 9 prior to engaging in a Settlement Conference; and 10 6. WHEREAS, the requested extensions will not unduly delay this case or prejudice any party, nor 11 is it made for any improper purpose. Rather, the request is made jointly by the parties and in a 12 timely manner. For this additional reason, good cause exists to grant the requested modification 13 to the schedule. See Ahanchian v. Xenon Pictures, Inc.,

(9th Cir. 2010) 14 (“requests for extensions of time made before the applicable deadline has passed should ‘normally 15 . . . be granted in the absence of bad faith on the part of the party seeking relief or prejudice to the 16 adverse party.’”) 17 NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties, by and through 18 their respective counsel of record, that: 19 1. The deadline to disclose expert witnesses shall be April 22, 2022; 20 2. The deadline to disclose rebuttal/supplemental expert witnesses shall be May 23, 2022; and 21 3. The deadline to file and serve pre-trial and or dispositive motions shall be July 22, 2022. 22 23 Date: January 27, 2022 GUIZAR, HENDERSON & CARRAZCO, LLP

24

25 By /s/ Christian Contreras Christian Contreras 26 Attorneys for Plaintiff 27 28 1 || Date: January 27, 2022 PORTER | SCOTT > A PROFESSIONAL CORPORATION 3 By/s/ William E. Camy 4 William E. Camy 5 Attorneys for Defendants 6 7 g ORDER 9 Upon review of the Joint Stipulation to Modify the Pre-Trial Scheduling Order and finding Good 10 Cause therefore, the Court hereby orders that the Initial Pre-Trial Scheduling Order dated February 3, 2021 (ECF 4) and the modification to that Order (ECF 10) be further modified as follows: D 1. The deadline to disclose expert witnesses shall be April 22, 2022; 2. The deadline to disclose rebuttal/supplemental expert witnesses shall be May 23, 2022; and 14 3. The deadline to file and serve pre-trial and or dispositive motions shall be July 22, 2022. 15 □□ /) IT IS SO ORDERED. \ | jf | ie “ okey 7 || DATED: January 27, 2022 —ZAK ZEN Troy L. Nunley } 18 United States District Judge 19 20 21 22 23 24 25 26 27 28

8 STIPULATION AND ORDER TO FURTHER MODIFY PRE-TRIAL SCHEDULING ORDER