Leonor v. City of Watsonville et al

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Stipulation to Continue Deadlines and [Proposed] Order (5:25-cv-06868-NC)
ROB BONTA
Attorney General of California
QUINTIN LUCAS
Supervising Deputy Attorney General
RUSSELL EMMONS
Deputy Attorney General
State Bar No. 289135
600 West Broadway, Suite 1800
San Diego, CA 92101
Telephone: (619) 738-9555
Fax: (916) 732-7920
E-mail: Russell.Emmons@doj.ca.gov
Attorneys for Defendants
Officer T. Kozisek, Officer L. Hernandez, and
Officer M. Negrete
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
CESAR LEONOR,
an individual,
Plaintiff,
v.
CALIFORNIA HIGHWAY PATROL
OFFICER T. KOZISEK, et al.,
Defendants.
5:25-cv-06868-NC
STIPULATION TO CONTINUE DATES
AND [PROPOSED] ORDER
Dept: 3
Judge: The Hon. Noel Wise
Trial Date: October 19, 2026
Action Filed: August 13, 2025
THE PARTIES STIPULATE AS FOLLOWS:
WHEREAS The Case has a Current Discovery Cutoff of March 6, 2026;
WHEREAS the parties have diligently sought to complete discovery but are waiting for
documents from third-party subpoenas;
WHEREAS the parties may require additional time in case additional motion work is
needed following subpoenas and the subsequent depositions.
Case 5:25-cv-06868-NW Document 29 Filed 02/23/26 Page 1 of 3

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Stipulation to Continue Deadlines and [Proposed] Order (5:25-cv-06868-NC)
THE PARTIES THEREFORE STIPULATE and request this Court vacate and reset the
following dates in accordance with the following schedule:
1. Discovery cutoff currently set for March 6, 2026 be reset to April 20, 2026.
2. Opening Expert Reports currently due April 3, 2026, be reset to May 18, 2026.
3. Rebuttal reports currently due May 1, 2026, be reset to June 15, 2026.
4. Dispositive motion deadline currently June 12, 2026 be reset to July 27, 2026
5. Hearing on Dispositive Motion to be heard August 5, 2026 be reset to September 18,
2026.
6. Trial set for October 19, 2026 to be set for December 3, 2026.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: February 19, 2026 Respectfully submitted,
ROB BONTA
Attorney General of California
CATHERINE WOODBRIDGE
Supervising Deputy Attorney General
/s/ Russell Emmons
RUSSELL EMMONS
Deputy Attorney General
Attorneys for Defendants
Officer T. Kozisek, Officer L. Hernandez, and
Officer M. Negrete
Dated: February 19, 2026 KENNETH C. ODIWE
LAW OFFICES OF KENNETH C. ODIWE, PC
/s/ Kenneth C. Odiwe
Attorneys for Plaintiff
Cesar Leonor
SF2025803763
85587199
Case 5:25-cv-06868-NW Document 29 Filed 02/23/26 Page 2 of 3

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Stipulation to Continue Deadlines and [Proposed] Order (5:25-cv-06868-NC)
[PROPOSED] ORDER
GOOD CAUSE APPEARING, and PURSUANT TO THE STIPULATION OF THE
PARTIES, the Court makes the following changes to currently schedule items.
1. Discovery cutoff currently set for March 6, 2026 be reset to April 20, 2026.
2. Opening Expert Reports currently due April 3, 2026, be reset to May 18, 2026.
3. Rebuttal reports currently due May 1, 2026, be reset to June 15, 2026.
4. Dispositive motion deadline currently June 12, 2026 be reset to July 27, 2026
5. Hearing on Dispositive Motion to be heard August 5, 2026 be reset to September 18,
2026.
6. Trial set for October 19, 2026 to be set for December 3, 2026.
THE HONORABLE DISTRICT JUDGE
NOEL WISE
The parties' stipulation is GRANTED in part, and DENIED in part without prejudice to refile as the
parties approach their latter deadlines.
Dated: February 23, 2026
Case 5:25-cv-06868-NW Document 29 Filed 02/23/26 Page 3 of 3