STIPULATED REQUEST FOR ORDER CHANGING DISCOVERY AND MOTION DATES SET IN COURT'S FEBRUARY 7, 2017, ORDER; [PROPOSED] ORDER AS MODIFIED

VINCE CHHABRIA, District Judge.

Plaintiff, BRANDY COLFESCU, and Defendants, LAWRENCE BERGER and FEDERAL LAW ENFORCEMENT OFFICERS ASSOCIATION, INC., (collectively the "Parties"), by and through their attorneys of record, hereby stipulate as follows:

RECITALS

A. The Complaint in this action was filed in September 2016.

B. On or around February 2017, the Parties agreed to, and thereafter stipulated to, participation in the Eastern District's Voluntary Dispute Resolution Program ("VDRP").

C. On May 18, 2017, this case was referred to VDRP pursuant to this Court's order. Bradley Benbrook was chosen by the Parties to act as the mediator for purposes of the VDRP.

D. Since that date, the Parties have been working to schedule a date for the VDRP session to take place. The VDRP session has been scheduled for August 10, 2017.

E. Because the Parties have agreed to, and will be, participating in the VDRP, the Parties have refrained from incurring unnecessary costs on expert witnesses, depositions, and other discovery.

F. Fact discovery is currently set to be cut off on August 18, 2017. However, the Parties wish to continue that date, along with all other discovery and motion dates in order to continue to work towards settlement at the VDRP session without incurring unnecessary costs.

G. In order to comply with the current deadlines set by the Court, the Parties will potentially be forced to needlessly incur costs in order to ensure that discovery is completed, when settlement is possible in just a few weeks.

H. As a result of the above, the Parties have agreed to continue all discovery and motion dates set in the Court's February 7, 2017, scheduling Order as set forth below.

STIPULATION

1. Fact discovery shall be completed by October 20, 2017.

2. The deadline for expert disclosure shall hereby be continued to October 20, 2017.

3. The deadline for expert rebuttal shall hereby be continued to November 8, 2017.

4. Expert discovery shall be completed by November 29, 2017.

5. Dispositive motions shall be filed by December 5, 2017. The Parties must contact the Court to obtain a date for a hearing in Sacramento.

IT IS SO STIPULATED.

[PROPOSED] ORDER AS MODIFIED

1. Fact discovery shall be completed by October 6, 2017.

2. The deadline for expert disclosure shall hereby be continued to October 6, 2017.

3. The deadline for expert rebuttal shall hereby be continued to October 20, 2017.

4. Expert discovery shall be completed by November 3, 2017.

5. Dispositive motions shall be filed by November 10, 2017. The Parties must contact the Court to obtain a date for a hearing in Sacramento.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

IT IS SO ORDERED AS MODIFIED.