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ALESA SCHACHTER (SBN 102542)

KELLIE M. MURPHY(SBN 189500)

JOHNSON SCHACHTER & LEWIS

A Professional Law Corporation

California Plaza

2180 Harvard Street, Suite 560

Sacramento, CA 95815

Telephone: (916) 921-5800

Facsimile: (916) 921-0247

Attorneys for Defendants LOS RIOS COMMUNITY COLLEGE DISTRICT, EUNYOUNG

HWANG, MARISSA SAYAGO, RICHARD BOOTH, and BRUCE WERNER

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

KATHLEEN BALL,

Plaintiff,

 v.

LOS RIOS COMMUNITY COLLEGE

DISTRICT, Educational subdivision of

Sacramento; EUNYOUNG HWANG, both

individually and in her capacity as acting Head

of the Art Department of the Los Rios

Community College District; MARISSA

SAYAGO, both individually and in her

capacity as Alternate Head of the Art

Department of the Los Rios Community

College District; RICHARD BOOTH, both

individually and in his capacity as 

Dean of Instruction of the Los Rios Community

College District; BRUCE WERNER, both

individually and in his capacity as Vice

President of the Folsom Lake/El Dorado and

Rancho Cordova Centers of the Los Rios

Community College District, and DOES 1 to

1000, inclusive;

Defendants.

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Case No. 2:04-cv-0970-MCE-JFM

STIPULATION REGARDING

PRETRIAL (STATUS) SCHEDULING

ORDER; ORDER 

IT IS STIPULATED by and between all parties, through their respective counsel, and with

the Court’s permission, that the dates set forth in the Status (Pre-Trial Scheduling) Order be changed

as follows:

Dispositive Motion Cut-off filing date: December 1, 2006;

Expert Witness Disclosure: October 1, 2006; and

Case 2:04-cv-00970-MCE -EFB Document 28 Filed 06/07/06 Page 1 of 3
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Discovery Cut-Off: October 1, 2006

All other dates in the Order shall remain, including the Trial and Pre-Trial Conference. The

parties submit that good cause existsto extend the dates as set forth below on the following grounds:

two motions to dismiss were filed (which were granted in part and denied in part), delaying the

pleading stage; the parties agreed to forego discovery until the pleadings were finalized to avoid

unnecessary time and expense; the parties are continuing to discuss the possibility of mediation

before substantial discovery is completed; the parties and witnesses have been unavailable at various

times throughout the litigation; and the issues remaining in this action are numerous and complex.

IT IS FURTHER STIPULATED that the discovery procedures set forth in Federal Rules of

Civil Procedure 26, 30, and 33 shall be modified as follows: 

1. All disclosures, including, but not limited to, initial disclosures as set forth in Rule

26(a), shall be waived; 

2. All limits associated with depositions, including the time limit for depositions and

the limit on the number of depositions, shall be waived;

3. The limit set forth in Rule 33 with respect to interrogatories shall be waived; 

4. The parties expressly reserve all rights to object on any grounds to written discovery

including, but not limited to, onerous and/orimproperly burdensome interrogatories;

and

5. All deposition dates will be coordinated with counsel.

IT IS SO STIPULATED.

DATED: 5/26/06 JOHNSON SCHACHTER & LEWIS

A Professional Law Corporation

 /s/ Kellie M. Murphy 

KELLIE M. MURPHY

Attorneys for Defendants

(SIGNATURES CONTINUED ON FOLLOWING PAGE)

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DATED: 5/26/06 LAW OFFICES OF FRANK J. DEBENEDETTO

 /s/ Frank J. DeBenedetto 

FRANK J. DEBENEDETTO

Attorneys for Plaintiff

IT IS SO ORDERED.

DATED: June 6, 2006

___________________________________

MORRISON C. ENGLAND, JR

UNITED STATES DISTRICT JUDGE

Case 2:04-cv-00970-MCE -EFB Document 28 Filed 06/07/06 Page 3 of 3