MAKSIM YARMALIUK v. COUNTY OF SACRAMENTO, JIM COOPER, MELISSA ANN PROPPS, SACRAMENTO COUNTY PROBATION DEPARTMENT, SACRAMENTO COUNTY SHERIFF’S DEPARTMENT

Opinion

Nicole M. Cahill, CSB No.: 287165 2 Alexander Mahoney, CSB No.: 359995 555 University Avenue, Suite 280 3 Sacramento, CA 95825 Phone: 916-974-8500 4 Facsimile: 916-974-8510 Emails: cahill@longyearlaw.com 5 mahoney@longyearlaw.com

6 Attorneys for Defendants, County of Sacramento [also sued as Sacramento 7 County Probation Department and Sacramento County Sheriff’s Department], Jim Cooper, and 8 Melissa Ann Propps

10 EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

11 MAKSIM YARMALIUK ) Case No.: 2:25-CV-01545-TLN-AC ) 12 Plaintiff, ) STIPULATION AND [PROPOSED] ) ORDER TO MODIFY THE 13 v. ) SCHEDULING ORDER ) COOPER, MELISSA ANN PROPPS, ) DEPARTMENT, SACRAMENTO COUNTY ) ) 17 Defendants. ) ) 18 19 Under Federal Rules of Civil Procedure 16(b)(1)(A) and Local Rule 143, the parties, 20 through counsel, stipulate to and hereby respectfully request a modification of this Court’s 21 scheduling order. Pursuant to the Court’s Initial Scheduling Order (ECF No. 11), the current 22 schedule is as follows: 23  Non-Expert Discovery Cut-off: May 15, 2026; 24  Expert Disclosures: June 15, 2026; 25  Supplemental Expert Disclosures: June 29, 2026; 26  Expert Discovery Cut-Off: July 29, 2026; 27  Dispositive Motion Deadline: September 29, 2026. 28 1 The parties in this case request an extension of the current schedule. The respective 2 deadlines would thus be as follows: 3  Non-Expert Discovery Cut-off: September 18, 2026; 4  Expert Disclosures: October 16, 2026; 5  Supplemental Expert Disclosures: November 20, 2026; 6  Expert Discovery Cut-Off: December 15, 2026; 7  Dispositive Motion Deadline: January 11, 2027. 8 A scheduling order may only be modified upon a showing of good cause and by leave 9 of Court. Fed. R. Civ. Proc. 6(b)(1)(A); Johnson v. Mammoth Recreations, Inc., 975 F.2d 10 604, 609 (9th Cir. 1992). In considering whether a party moving for a schedule modification 11 has good cause, the Court primarily focuses on the diligence of the party seeking the 12 modification. Johnson, 975 F.2d at 609. 13 Plaintiff served Defendants with his initial disclosures on July 21, 2025. Defendants 14 served their initial disclosures on Plaintiff on August 18, 2025. (Declaration of Alexander 15 Mahoney (“Mahoney Decl.”) ¶ 2.) Plaintiff served Defendants with written discovery on 16 September 16, 2025. (Mahoney Decl., ¶ 3.) Plaintiff’s initial written discovery included a 17 request for production of documents. (Mahoney Decl., ¶ 4.) Plaintiff has subsequently served 18 multiple rounds of additional discovery on Defendants. (Mahoney Decl., ¶ 5.) On March 19, 19 2026, the parties met and conferred regarding discovery in this case and Plaintiff’s intent to 20 file a first amended complaint. (Mahoney Decl., ¶ 6.) Considering the volume of discovery 21 Plaintiff has served on Defendants as well as the discovery the parties still plan to conduct, 22 the parties have agreed to seek an extension of the current scheduling order. (Mahoney Decl., 23 ¶ 7.) This extension is intended to allow the parties to complete discovery and resolve any 24 outstanding disputes. (Mahoney Decl., ¶ 8.) For these reasons, good cause exists to modify 25 the Court’s scheduling order, including both the deadlines identified above and any related 26 dates. 27 / / / 28 / / / 2 3 Dated: April 27, 2026 LONGYEAR, LAVRA & CAHILL, LLP

4 By: /s/ Alexander Mahoney 5 NICOLE M. CAHILL Attorneys for Defendants, 7 County of Sacramento, Jim Cooper and Melissa Dawn Propps 8 9 10 Dated: April 27, 2026 PLAINTIFF IN PRO SE

12 By: MAKSIM YARMALIUK, Plaintiff 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 [PROPOSED] ORDER 2 Good cause appearing, the parties’ stipulated request to modify the Court’s 3 || Scheduling Order (ECF No. 11) is GRANTED. 4 The relevant deadlines are ordered as follows: 5 o Non-Expert Discovery Cut-off: September 18, 2026; 6 o Expert Disclosures: October 16, 2026; 7 o Supplemental Expert Disclosures: November 20, 2026; g o Expert Discovery Cut-Off: December 15, 2026; 9 o Dispositive Motion Deadline: January 11, 2027. 10 11 |] DATED: April 28, 2026 ~ 12 Chttien— Clare UNITED STATES MAGISTRATE JUDGE 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

4. STIPULATION AND [PROPOSED] ORDER TO MODIFY THE SCHEDULING ORDER