STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO CONDUCT COURT-ORDERED DEPOSITIONS OF PLAINTIFF STEVEN BUSTER AND DIANNE FELTON OF MECHANICS BANK

[Filed concurrently with Declaration of Joseph C. Faucher pursuant to L-R 6-2(a)]

WILLIAM ALSUP, District Judge.

Defendants COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS OF MECHANICS BANK; MECHANICS BANK SUPPLEMENTAL EXECUTIVE RETIREMENT PLAN and MECHANICS BANK (collectively, "Defendants") and Plaintiff Steven K. Buster ("Plaintiff") (together hereafter the "Parties") hereby stipulate and agree, by and through their respective counsel, to extend the time for the Parties to conduct the court-ordered depositions of Plaintiff Steven Buster and Dianne Felton of Mechanics Bank, to now take place on July 6, 2016.

WHEREAS, on June 9, 2016, the Court ordered that one-hour depositions of Plaintiff Steven Buster and Dianne Felton shall be taken on or before June 30, 2016, and specifically to take place on June 27, 2016 at 9:00 a.m. at the offices of Plaintiff's counsel, Louderback Law Group, located at 44 Montgomery Street, Suite 2970, San Francisco, California 94104. (Docket #41.)

WHEREAS, good cause exists to extend the time to take the depositions of Plaintiff Steven Buster and Dianne Felton by reason of the fact that Dianne Felton is largely unavailable during the entire month of June. To accommodate their respective schedules, and at the same time proceed with the depositions at the earliest possible date, the Parties have agreed to proceed with the one-hour depositions of Plaintiff Steven Buster and Dianne Felton on July 6, 2016 at 9:00 a.m. at the offices of Plaintiff's counsel, Louderback Law Group, located at 44 Montgomery Street, Suite 2970, San Francisco, California 94104.

The Parties have not requested any prior extensions of time to conduct the depositions of Plaintiff Steven Buster or Dianne Felton. Prior time modifications in this case, whether by stipulation or Court order, include: (1) Defendants previously obtained a thirty (30) day extension of time, from April 6, 2016 to May 6, 2016, to respond to the original Complaint in this matter, by stipulation; (2) the Court issued an Order Extending Deadlines for Response and Reply Papers re Defendants' Motion to Dismiss on May 18, 2016 (Docket #28); and (3) the Court issued an Order Extending Time for Defendants to Respond to Plaintiff's Amended Complaint on June 9, 2016 (Docket #39). The proposed order extending the time to conduct said depositions to July 6, 2016 will not alter the date of any event or any deadline already fixed by Court order in this matter. This Stipulation is made and entered into pursuant to Local Rules 6-1(b) and 6-2(a).

THE PARTIES THEREFORE AGREE AND STIPULATE AS FOLLOWS:

The depositions of Plaintiff Steven K. Buster and Dianne Felton of Mechanics Bank will now take place on July 6, 2016 at 9:00 a.m. at the offices of Plaintiff's counsel, Louderback Law Group, located at 44 Montgomery Street, Suite 2970, San Francisco, California 94104.

I attest that I have obtained Mr. Louderback's concurrence in the filing of this document.

PURSUANT TO STIPULATION, IT IS SO ORDERED.