KAMALA D. HARRIS, Attorney General of California, DAMON G. McCLAIN, Supervising Deputy Attorney General, SHARON A. GARSKE, Deputy Attorney General, State Bar No. 215167 San Francisco, CA, Attorneys for Defendants, CDCR, Cate, and Lewis.
WILLIAM L. SCHMIDT, Attorney at Law, P.C., State Bar No. 206870, Fresno, CA, Attorneys for Plaintiffs, Machado and Garcia.
JOINT STIPULATED REQUEST FOR ORDER CHANGING TIME FOR EXCHANGING INITIAL DISCLOSURES AND CASE MANAGEMENT CONFERENCE SCHEDULED FOR JULY 11, 2013; [PROPOSED] ORDER
JACQUELINE S. CORLEY, Magistrate Judge.
Pursuant to Civil L.R. 6-2, Plaintiff Machado and Garcia (Plaintiffs) and Defendants California Department of Corrections and Rehabilitation (CDCR), Cate, and Lewis (Defendants) (the "Parties"), by and through their respective counsel of record, hereby stipulate to change the time for exchanging initial disclosures set for July 5, 2013 and request that the Case Management Conference scheduled for July 11, 2013 before Magistrate Judge Jacqueline S. Corley be continued to a reasonable date as decided by the Court for the following reasons:
I. REASONS FOR THE CHANGE OF TIME
Defendants counsel was recently assigned to the case and is still in the process of obtaining records concerning the events pertaining to this case and interviewing clients and witnesses. Plaintiffs' counsel has indicated that he may file an amended complaint.
The parties believe that a later date for exchanging initial disclosures and the initial Case Management Conference serves the interests of judicial and party efficiency.
II. PREVIOUS TIME MODIFICATIONS
The Court granted Plaintiffs' request for an extension of time to serve Defendants with the summons and complaint. (Order Discharging Show Cause Order and Directing Issuance of Summons, May 1, 2013, ECF No. 19.)
III. EFFECT THE REQUESTED TIME MODIFICATION WILL HAVE ON SCHEDULE
The Parties respectfully request the Court to reschedule the Case Management Conference scheduled for July 11, 2013 to a date that is convenient for the Court. And the Parties request that the Court set the deadline for initial disclosures to a new date in accordance with the new date for the Case Management Conference. Plaintiff's counsel requests that he be permitted to telephonically attend the Case Management Conference.
PURSUANT TO STIPULATION, IT IS ORDERED:
1. The date for initial disclosures will be reset in accordance with the new date for the ...