ORDER

JOINT STIPULATION TO EXTEND V. NON-EXPERT DISCOVERY DEADLINE (Proposed)

RICHARD SEEBORG, District Judge.

TO THIS HONORABLE COURT:

By and through their counsel, Plaintiff J & J Sports Productions, Inc., Defendants/Third-Party Plaintiffs/Counter-Defendants Blanca E. Bouton, Jose David Monterrubio, and Third-Party Defendants/Counter-Claimants DirecTv, LLC and DirecTv International, Inc. hereby agree, stipulate, and respectfully request that this Honorable Court extend the non-expert discovery deadline in this action, presently set for March 1, 2016, to a new date approximately sixty (60) days forward, and in support aver as follows:

WHEREAS, there is presently a non-expert discovery deadline of March 1, 2016, scheduled in this action (ECF #66).

WHEREAS, Defendants Blanca E. Bouton and Jose David Monterrubio wish to conduct the deposition of Mr. Joseph M. Gagliardi, President of J & J Sports Productions, Inc., as well as the deposition of the Person Most Knowledgeable of Plaintiff J & J Sports Productions, Inc.

WHEREAS, Joseph M. Gagliardi, President and Person Most Knowledgeable of J &J Sports Productions, Inc. is not available for deposition prior to presently existing non-expert discovery deadline of March 1, 2016.

WHEREAS, the trial in this action is presently scheduled for September 19, 2016 (ECF #66).

WHEREAS, this is the first extension of the non-expert discovery deadline being requested by the Parties and the Parties do not anticipate any further extension of this particular extension of deadline will be necessary.

WHEREFORE, The Parties respectfully request that this Honorable Court extend the non-expert discovery deadline in the above-entitled action, presently set for March 1, 2016, to a new date (May 1, 2016) approximately sixty (60) days forward.

ORDER (Proposed)

IT IS HEREBY ordered that the non-expert discovery deadline in the above-entitled action is hereby extended from March 1, 2016 to May 31, 2016.

IT IS SO ORDERED: