LONGYEAR, LAVRA & CAHILL, LLP 1 Van Longyear, CSB No.: 84189 Nicole M. Cahill, CSB No.: 287165 2 555 University Avenue, Suite 280 Sacramento, CA 95825 3 Phone: 916-974-8500 Facsimile: 916-974-8510 4 Email: [email protected] [email protected] 5

6 Attorneys for Defendants, County of Sacramento, Deputy Andrew Patterson, 7 Deputy Andrew Falvey, Deputy Najee Burge

8 UNITED STATES DISTRICT COURT

9 EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

10

11 JOSEPH AMEY, as an individual, and ) Case No.: 2:24-CV-02232-TLN-CSK WARREN AMEY, as an individual ) 12 ) STIPULATION AND ORDER TO Plaintiffs ) MODIFY THE SCHEDULING ORDER 13 ) v. ) 14 ) ANDREW PATTERSON, as an individual, ) 15 ANDREW FALVEY, as an individual, ) NAJEE BURGE, as an individual, and ) 16 COUNTY OF SACRAMENTO, as a ) municipal corporation, ) 17 ) Defendants. ) 18 ) 19 Under Federal Rules of Civil Procedure 16(b)(1)(A) and Local Rule 143, the parties, 20 through counsel, stipulate to and hereby respectfully request a modification of this Court’s 21 scheduling order. Pursuant to the Court’s Initial Scheduling Order (ECF No. 3) and the parties’ 22 Joint Status Report (ECF No. 6), the current schedule is as follows: 23  Fact discovery cut off: October 16, 2025 24  Expert witness disclosure: December 14, 2025 25  Supplemental expert disclosure: January 13, 2026 26  Dispositive motion deadline: April 13, 2026 27 The parties in this case request an extension of the current schedule by ninety days. The 28 respective deadlines would thus be as follows: 1  Fact discovery cut off: January 14, 2026 2  Expert witness disclosure: March 14, 2026 3  Supplemental expert disclosure: April 13, 2026 4  Dispositive motion deadline: July 12, 2026 5 A scheduling order may only be modified upon a showing of good cause and by leave of 6 Court. Fed. R. Civ. Proc. 6(b)(1)(A); Johnson v. Mammoth Recreations, Inc.,

, 609 7 (9th Cir. 1992). In considering whether a party moving for a schedule modification has good 8 cause, the Court primarily focuses on the diligence of the party seeking the modification.

F.2d at 609. 10 The parties exchanged initial disclosures on March 14, 2025. Defendants’ disclosures 11 contained an extensive amount of videos and other media. (Cahill Decl. ¶ 2.) Shortly thereafter, 12 the parties opted to attempt to resolve the matter through a settlement conference prior to 13 undertaking substantial discovery. On April 25, 2025, the Court set a settlement conference 14 before Judge Riordan on June 17, 2025. (ECF No. 7.) The case did not resolve at the settlement 15 conference. (ECF No. 13.) Following the settlement conference, Defendants served Rule 68 16 offers to Plaintiffs on August 27, 2025, but Plaintiffs did not accept. (Cahill Decl., ¶ 4.) During 17 these settlement efforts, the parties agreed to an informal stay of discovery. (Cahill Decl., ¶ 4.) 18 As it became apparent that the matter would not settle, on September 12, 2025, counsel for 19 Defendants reached out to Plaintiffs’ counsel to determine whether the parties required more 20 time conduct discovery. (Cahill Decl., ¶ 5.) On October 8, 2025, Plaintiffs’ counsel agreed to 21 extend deadlines as sought in this proposal so that the parties could conduct additional discovery. 22 (Cahill Decl., ¶ 6.) 23 For these reasons, good cause exists to modify the fact discovery cut off deadline and 24 related court deadlines. 25 IT IS SO STIPULATED. 26 / / / 27 / / / 28 / / / 1 Dated: October 16, 2025 LONGYEAR, LAVRA & CAHILL, LLP 2 By:_/a/ Nicole M. Cahill 3 VAN LONGYEAR 4 NICOLE M. CAHILL Attorneys for Defendants, 5 County of Sacramento, Deputy Andrew Patterson, Deputy Andrew Falvey, Deputy 6 Najee Burge 7 || Dated: October 16, 2025 LAW OFFICE OF KELLAN PATTERSON 8 9 By:_/s/ Kellan Patterson [as authorized 10-16-25] KELLAN PATTERSON 10 Attorney for Plaintiffs 1] 12 13 14 ORDER 15 Good cause appearing, the parties’ stipulated request to modify the Court’s Scheduling 16 || Order (ECF No. 3) is GRANTED. 17 The relevant deadlines are ordered as follows: 18 o Fact discovery cut off: January 14, 2026 19 o Expert witness disclosure: March 16, 2026 20 o Supplemental expert disclosure: April 13, 2026 7] o Dispositive motion deadline: July 13, 2026 22 23 || DATED: October 16, 2025 24 25 Troy L. Nunley Chief United States District Judge 27 28

STIPULATION AND ORDER TO MODIFY THE SCHEDULING ORDER