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STIPULATION AND PROPOSED ORDER REGARDING SCHEDULING

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BRUCE A. KILDAY, ESQ., SBN. 66415 (SPACE BELOW FOR FILING STAMP ONLY)

ANGELO, KILDAY & KILDUFF 

Attorneys at Law 

601 University Avenue, Suite 150 

Sacramento, CA 95825 

Telephone: (916) 564-6100 

Telecopier: (916) 564-6263 

Attorneys for Defendants 

CITY OF DIXON, MAYOR MARY ANN COURVILLE, 

VICE-MAYOR GIL VEGA, COUNCILMAN LOREN FERRERO, 

COUNCILWOMAN JILL DISNEY ORR, CITY MANAGER 

WARREN SALMONS, DIXON POLICE DEPARTMENT, 

POLICE CHIEF DON MORT AND POLICE CAPTAIN LOU KALISH 

WILLIAM C. COLLIER, SBN 163005 

McDonald Collier 

3882 Pinecrest Drive 

Mariposa, CA 95338 

Telephone: (209) 742-6622 OK/HAV 

Telecopier: (209) 742-6655 

Attorneys for Plaintiff 

MICHAEL CEREMELLO 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

MICHAEL CEREMELLO, 

 Plaintiff, 

vs. 

CITY OF DIXON, et al., 

Defendants. 

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Case No.: CIV S-04-1423 DFL PAN 

STIPULATION AND PROPOSED 

ORDER REGARDING SCHEDULING 

All parties, through their respective counsel, submit that there is good cause to reschedule 

the trial and relevant dates in this matter. WHEREAS: 

A. This case involves activities over a period of time and therefore the discovery of 

multiple documents, activities and public meetings; 

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STIPULATION AND PROPOSED ORDER REGARDING SCHEDULING

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B. The depositions of a dozen or more witnesses are anticipated; 

C. Scheduling conflicts of various public officers and the plaintiff make discovery 

unusually time consuming; 

D. Discovery which calls for the disclosure of privileged material is anticipated to lead to 

disputes which may ultimately be resolved by the magistrate, and therefore take more time than 

had initially been anticipated. 

E. Recent discovery findings of new information that both parties need more time to 

review before conducting depositions. 

Therefore, the parties through their respective counsel, stipulate to the revised schedule 

for this litigation and request that the Court approve it. 

PROPOSED DATE CURRENT DATE

Trial [February 5, 2007] [October 23, 2006] 

Pretrial Conference [December 15, 2006 

@ 3:00 p.m.] 

[September 1, 2006] 

Joint Pre-Trial Statement [December 8, 2006] 

Dispositive Motion 

Hearing 

[November 1, 2006 

@ 10:00 a.m.] 

[July 19, 2006 

@ 10:00 a.m.] 

Dispositive Motion Filing September 27, 2006] June 21, 2006 

Discovery Cut-Off [August 257, 2006] May 5, 2006 

Expert Disclosure June 16, 2006 February 1, 2006 

Supplemental Expert 

Disclosure 

June 30, 2006 February 15, 2006 

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STIPULATION AND PROPOSED ORDER REGARDING SCHEDULING

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Dated: May 3, 2006 ANGELO, KILDAY & KILDUFF 

By:_/s/ Bruce A. Kilday________________ 

BRUCE A. KILDAY 

Attorneys for Defendants 

CITY OF DIXON, MAYOR MARY 

ANN COURVILLE, VICE-MAYOR 

GIL VEGA, COUNCILMAN LOREN 

FERRERO, COUNCILWOMAN JILL 

DISNEY ORR, CITY MANAGER 

WARREN SALMONS, DIXON 

POLICE DEPARTMENT, POLICE 

CHIEF DON MORT AND POLICE 

CAPTAIN LOU KALISH 

Dated: April 28, 2006 

By: /s/ William C. Collier

Attorneys for Plaintiff 

MICHAEL CEREMELLO 

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ORDER

The Court is satisfied that good cause exists and hereby adopts the proposed schedule. 

PROPOSED DATE CURRENT DATE

Trial [February 5, 2007] [October 23, 2006] 

Pretrial Conference [December 15, 2006 

@ 3:00 p.m.] 

[September 1, 2006] 

Joint Pre-Trial Statement [December 8, 2006] 

Dispositive Motion 

Hearing 

[November 1, 2006 

@ 10:00 a.m.] 

[July 19, 2006 

@ 10:00 a.m.] 

Dispositive Motion Filing [September 27, 2006] June 21, 2006 

Discovery Cut-Off [August 25, 2006] May 5, 2006 

Expert Disclosure June 16, 2006 February 1, 2006 

Supplemental Expert 

Disclosure 

June 30, 2006 February 15, 2006 

Dated: May 3, 2006 /s/ David F. Levi 

DAVID F. LEVI 

Judge of the U.S. District Court 

 

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