1 VCiEtyR AOtNtoIrCneAy ,A S.BFN. N 1E4B00B0 1 2 BY: KRISTOFFER S. JACOB Assistant City Attorney, SBN 320286 3 CITY OF VALLEJO, City Hall 555 Santa Clara Street, Third Floor 4 Vallejo, CA 94590 Tel: (707) 648-4545 5 Fax: (707) 648-4687 Email: [email protected] 6 Attorneys for Defendants CITY OF VALLEJO, 7 JASON TA and JODI BROWN

8 UNITED STATES DISTRICT COURT

9 FOR THE EASTERN DISTRICT OF CALIFORNIA

10 JAMAL COLTER, an individual; Case No. 2:25-cv-01104-AC KELLYANNE COLTER, an individual; and 11 ROBERT BAKER, an individual, STIPULATION AND ORDER TO STAY 12 Plaintiffs, CASE PENDING RESOLUTION OF CRIMINAL ACTION 13 v.

14 CITY OF VALLEJO, a municipal corporation; JASON TA, in his official 15 capacity as CHIEF OF POLICE for the CITY OF VALLEJO; JODI BROWN, in her 16 individual capacity as a law enforcement officer for the CITY OF VALLEJO; and 17 DOES 1-25 in their individual capacity as law enforcement officers for the CITY OF 18 VALLEJO, inclusive,

19 Defendants.

20 21 IT IS HEREBY STIPULATED by and between Plaintiffs JAMAL COLTER, an 22 individual; KELLYANNE COLTER, an individual; and ROBERT BAKER, an individual 23 (“Plaintiffs”), and Defendants CITY OF VALLEJO, a municipal corporation; JASON TA, in his 24 official capacity as CHIEF OF POLICE for the CITY OF VALLEJO; JODI BROWN, in her 25 individual capacity as a law enforcement officer for the CITY OF VALLEJO (“Defendants”), 26 referred to collectively as the “Parties,” by and through their designated counsel that: 27 WHEREAS, this case arises from a series of incidents involving multiple encounters 28 between Plaintiffs and officers from the Vallejo Police Department ("VPD"); 1 WHEREAS, the District Attorney brought multiple charges against Plaintiff Robert 2 Baker in connection with his encounter with VPD officers, which case is currently pending in the 3 Solano County Superior Court, Case No. F24-02463; 4 WHEREAS, Plaintiffs’ claims against Defendants in the underlying civil action rely in 5 part on Plaintiff Baker’s encounter with VPD officers that resulted in the criminal charges now 6 pending in the Solano County Superior Court; 7 WHEREAS, a conviction in the criminal case may bar some or all of Plaintiffs’ claims 8 against Defendants under Heck v. Humphrey,

(1994); 9 WHEREAS, California Government Code section 945.3 precludes Plaintiffs from 10 litigating their claims under state law against the individually named and Doe officers and the 11 City of Vallejo while the criminal case is pending; 12 WHEREAS, the Parties believe that a stay is appropriate; and 13 WHEREAS, the Parties will notify the Court within thirty (30) days of the resolution of 14 the underlying criminal case. 15 IT IS HEREBY STIPULATED, by and between the Parties to this action through their 16 counsel that this case be stayed pending resolution of criminal proceedings against Plaintiff 17 Robert Baker currently pending in the Superior Court of Solano County. 18 Respectfully submitted,

19 DATED: July 14, 2025 /s/ Kristoffer S. Jacob Kristoffer S. Jacob 20 Assistant City Attorney Attorney for Defendants 21 CITY OF VALLEJO, JASON TA and JODI BROWN 22

23 NOLD LAW

24 DATED: July 14, 2025 /s/ Melissa C. Nold (as authorized on 07/14/2025) Melissa C. Nold 25 Attorney for Plaintiffs JAMAL COLTER, KELLYANNE COLTER and 26 ROBERT BAKER 27 28 1 ORDER 2 Pursuant to the stipulation of the Parties and good cause appearing, Colter v. City of 3 Vallejo, Case No. 2:25-cv-01104-AC is stayed pending the resolution of People v. Baker, Case 4 No. F24-02463. The Parties are ordered to notify the Court within thirty (30) days of the 5 resolution of the underlying criminal case. 6 IT IS SO ORDERED. 7 8 DATED: July 15, 2025 ~ 9 Httven— Lhar—e_ ALLISON CLAIRE 10 UNITED STATES MAGISTRATE JUDGE 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIP AND ORDER TO STAY CASE