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STIPULATION AND PROPOSED ORDER 

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STEPHEN L. DAVIS (State Bar No. 149817) 

MARK R. LEONARD (State Bar No. 219186) 

DAVIS & LEONARD, LLP 

8880 Cal Center Drive 

Suite 180 

Sacramento, California 95826 

Telephone: (916) 362-9000 

Fax: (916) 362-9066 

E-mail: mleonard@davisandleonard.com

Attorneys for Plaintiff 

Jason Isaksen 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

JASON ISAKSEN, an individual, 

 Plaintiff, 

v. 

MAZU PUBLISHING COMPANY, an Oregon 

Corporation, and MATTHEW GAGNON, an 

individual, 

 Defendants. 

CASE NO. CV. S-04-2240 WBS CMK 

STIPULATION AND [PROPOSED] ORDER 

RE: MODIFICATION OF PRETRIAL 

SCHEDULING ORDER 

The parties to the above action hereby apply for an order providing that the parties 

shall have until November 30, 2005, to complete discovery and December 5, 2005, to file 

motions. The parties also request that the final pre-trial conference be held on or after 

January 23, 2005 at 10:00 a.m., with the jury trial to begin on or after March 7, 2006 at 

9:00 a.m. 

The parties’ application is based on the following: The parties have conducted 

substantial discovery in the case, but prior to undertaking depositions, which would require 

out-of-state travel by the parties’ counsel, the parties began settlement negotiations in the 

hope of resolving this matter before incurring significant additional expenses. Those 

negotiations are continuing and are likely to continue beyond the current discovery cut off 

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STIPULATION AND PROPOSED ORDER 

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date of September 19, 2005. The parties believe that good cause exists for modifying the 

current scheduling order deadlines because, if the settlement negotiations are not 

successful, the new deadlines will permit the parties to complete their discovery while still 

allowing an expeditious resolution of the case. 

Dated: September 13, 2005. 

DAVIS & LEONARD, LLP 

s/ Mark R. Leonard

Mark R. Leonard 

Attorney for Plaintiff 

Jason Isaksen 

 

Dated: September 13, 2005. 

ANTHONY DEGIDIO 

ATTORNEY AT LAW 

s/ Anthony J. DeGidio

Anthony J. DeGidio 

Attorney for Defendants 

Matthew Gagnon and Mazu Publishing Co. 

Dated: September 13, 2005. 

MALOVOS & MENDOZA, LLP 

s/ Joanna R. Mendoza

Joanna R. Mendoza 

Attorney for Defendants 

Matthew Gagnon and Mazu Publishing Co. 

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STIPULATION AND PROPOSED ORDER 

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GOOD CAUSE APPEARING, IT IS SO ORDERED: 

The discovery cutoff date in this matter shall be continued until November 30, 

2005, and the deadline to file motions shall be December 5, 2005. The final pre-trial 

conference shall be held on __January 30____, 2006 at 10:00 a.m., with the jury trial to 

begin __March 21____, 2006, at 9:00 a.m. 

Dated: September 14, 2005 

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