IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 29, 2009
MAGGIE FRANKLIN, PLAINTIFF,
SACRAMENTO AREA FLOOD CONFERENCE CONTROL AGENCY, A PUBLIC ENTITY, CITY OF SACRAMENTO, A PUBLIC AGENCY, DEFENDANTS.
FOURTH JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER AND CONTINUE THE FINAL PRE-TRIAL
Complaint Filed: June 26, 2007
1st Amended Complaint Filed: June 16, 2008
Plaintiff MAGGIE FRANKLIN and Defendants SACRAMENTO AREA FLOOD CONTROL AGENCY, and the CITY OF SACRAMENTO, by and through their respective attorneys of record, hereby stipulate and request the Court to further modify the Pre-Trial Scheduling Order by continuing the Final Pre-Trial Conference from February 23, 2009 to April 6, 2009. Jury trial in this case is currently scheduled for May 27, 2009.
Good cause exists to continue the Final Pre-Trial Conference because Defendants' Motion for Summary Judgment, or in the Alternative, Partial Summary Judgment ("Defendants' Motion") against all of Plaintiff's nine claims for relief is currently pending before the Court. Since the hearing for Defendants' Motion is set for March 2, 2009, the Final Pre-Trial Conference is scheduled to occur before the Court rules on Defendants' Motion. The parties believe obtaining the Court's ruling on Defendants' Motion for Summary Judgment before preparing their Separate Pre-Trial Statements will result in the more efficient and effective use of the Court's time and resources. For this reason, the parties respectfully request the Court continue the Final Pre-Trial Conference from February 23, 2009 to April 6, 2009 at 2:00 p.m.
A PROFESSIONAL CORPORATION
January 26, 2009
Carl L. Fessenden
James S. Yi Attorneys for Defendants
MURRAY & ASSOCIATES
January 26, 2009
Lawrence D. Murray (as authorized on 1/26/09) Attorney for Plaintiff
IT IS SO ORDERED.
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