2 Omar G. Qureshi (Cal. Bar No. 323493) [email protected] 3 Max A. Schoening (Cal Bar No. 324643) [email protected] 4 700 Flower Street, Suite 1000 Los Angeles, California 90017 5 Telephone: (213) 786-3478 6 Fax: (213) 277-8989 7 Attorneys for Shan Valencia Thomas

8 RIVERA HEWITT PAUL LLP SHANAN L. HEWITT. SBN 200168 9 WENDY MOTOOKA, SBN 233589 2355 Gold Meadow Way, Suite 170 10 Gold River, California 95670 11 Telephone: 916-922-1200 Fax: 916 922-1303 Email: [email protected] 12 [email protected]

13 Attorneys for Defendants COUNTY OF STANISLAUS, 14 KYLE CHRISTIANSON, and ERIC GARCIA

15 UNITED STATES DISTRICT COURT 16 EASTERN DISTRICT OF CALIFORNIA 17

18 SHAN VALENCIA THOMAS, Case No.: 2:25-cv-02113-WBS-CKD 19

20 Plaintiff, STIPULATION FOR EXTENSION OF 21 TIME FOR PLAINTIFF TO FILE THE v. FIRST AMENDED COMPLAINT; 22 ORDER THEREON 23 STANISLAUS COUNTY, KYLE CHRISTIANSON, ERIC GARCIA, and 24 DOES 1-10, inclusive, 25 Defendants. 26

27

28 2 TO THE HONORABLE COURT:

3 WHEREAS plaintiff filed the Complaint in this matter on July 29, 2025, but served the

4 defendants on different dates; 5 WHEREAS Defendant STANISLAUS COUNTY filed a motion to dismiss the 6 Complaint on August 29, 2025, set for hearing on October 27, 2025 (ECF No. 7); 7 WHEREAS Defendants KYLE CHRISTIANSON and ERIC GARCIA filed a motion to 8 dismiss the Complaint on September 11, 2025, also set for hearing on October 27, 2025 (ECF 9 No. 8), which asserts that the pending claims are barred by Heck v. Humphrey,

(1994); 11 WHEREAS in response to the pending motions to dismiss, Plaintiff intends to file an 12 amended complaint as of right, but seeks an extension of time to October 29, 2025 in which to 13 do so, because of plaintiff’s counsel’s trial schedule; and 14 WHEREAS the Pretrial Conference is set for December 1, 2025 (ECF No. 3), requiring 15 the Rule 26(f) conference to be conducted by November 10, 2025, which would be before 16 defendants’ response would be due to an amended complaint filed on October 29, 2025; 17 THEREFORE the parties, by and through their respective counsel of record, hereby 18 stipulate as follows: 19 1. Plaintiff shall have an extension of time up to and including October 29, 2025, to 20 file an amended pleading as of right; 21 2. Defendants’ currently pending motions to dismiss the Complaint shall be 22 vacated as moot, without prejudice to being refiled if no amended pleading is filed within the 23 required time; 24 3. If and when the amended pleading is filed, defendants may respond to the 25 amended pleading in any manner authorized by Federal Rule of Civil Procedure 12; and 26 4. The Pretrial Conference set for December 1, 2025 and associated dates should be 27 vacated and re-set for a later date at the Court’s convenience. 28 IT IS SO STIPULATED. 1 2 Dated: September 12, 2025 By: /s/ Max Schoening Max A. Schoening 3 Omar G. Qureshi 4 Attorneys for Plaintiff Shan Valencia Thomas 5 6 Dated: September 12, 2025 By: _/s/ Wendy Motooka 7 SHANAN L. HEWITT WENDY MOTOOKA 8 Attorneys for Defendants STANISLAUS 9 COUNTY, KYLE CHRISTIANSON, and ERIC GARCIA 10 M ORDER = 2 Pursuant to the Stipulation of the parties, and good cause appearing, it is hereby = 2 | ORDERED that:

2 14 1. Plaintiff may file the First Amended Complaint on or before October 29, 2025; oO BO 15 2. Defendants’ pending motions to dismiss [ECF Nos. 7 & 8] are VACATED as

= Oo 2 16 moot, without prejudice;

S a RS M 3. Defendants may respond to the First Amended Complaint in any manner 18 authorized by Federal Rule of Civil Procedure 12; 19 20 4. The Scheduling Conference set for December 1, 2025 is RESET for February 1 9, 2026 at 1:30 p.m. A joint status report shall be filed no later than January 26, 2026 in 22 || accordance with the Court’s Order Re: Status (Pretrial Scheduling) Conference filed July 29, 23 || 2025 (Docket No. 3). 24 IT IS SO ORDERED. . - 25 ed blew th, b~-— Dated: September 15, 2025 WILLIAMB.SHUBB UNITED STATES DISTRICT JUDGE 27 28

STIPULATION FOR EOT FOR PLAINTIFF TO FILE AN AMENDED COMPLAINT -3-