AMENDED1 JOINT STIPULATION AND ORDER TO CONTINUE PRETRIAL DEADLINES

MORRISON C. ENGLAND, Jr., Chief District Judge.

Pursuant to Federal Rule of Civil Procedure 16(b) and Eastern District Local Rule 143, Defendants Superior Court of California, County of Shasta2 and Joel Dean (collectively, "Defendants") and Plaintiffs Jaime Schmidt, Debra Knowles, Elizabeth Sampson and Ryan Henrioulle ("Plaintiffs") hereby stipulate and agree as follows.

WHEREAS, on October 21, 2014, Plaintiffs filed their Complaint (Docket No. 1) in this action. In their Complaint, Plaintiffs allege that, while employed in the Marshal's Office of the Superior Court of California, County of Shasta, they were subjected to discrimination, harassment and retaliation, in violation of federal and state discrimination laws.

WHEREAS, on December 12, 2014, Defendants filed an Answer (Docket No. 6) to Plaintiffs' Complaint, denying Plaintiffs' claims in their entirety and asserting a variety of separate and additional defenses.

WHEREAS, on April 10, 2015, the Court issued a Pretrial Scheduling Order (Docket No. 10), setting various pretrial and trial deadlines, including a January 22, 2016 deadline for completing discovery and a July 14, 2016 deadline for hearing any dispositive motions.

WHEREAS, to date, the parties have completed some discovery in this matter. For example, in June 2015, the parties exchanged initial disclosures. Moreover, in September 2015, Defendants propounded some written discovery on Plaintiffs, to which Plaintiffs, after receiving a three-week extension, recently responded to.

WHEREAS, due to the fact that there are four individual Plaintiffs (each with their own separate sets of employment histories, factual allegations and legal claims), the parties do not believe they will be able to complete discovery in this matter by the January 22, 2016 deadline. This is particularly so given that in order to complete discovery by the current deadline, the parties would have to complete all depositions within the next two months (notwithstanding the upcoming holidays).

WHEREAS, the parties anticipate that additional time will assist in their respective prosecution and defense of this action and wish to continue the pretrial deadlines set forth in the Court's Pretrial Scheduling Order by approximately 90 days (see chart below). In light of the above circumstances, and given that neither party has previously requested an extension of any of the pretrial dates set in this matter, pursuant to Rule 16(b)(4) good cause exists for the relief requested herein.

NOW THEREFORE, based on the foregoing, the parties respectfully request that the Court continue the pretrial deadlines in the following manner:

IT IS SO STIPULATED.

ORDER

The Court adopts the parties' stipulation, with the dates modified by the Court, as its order.

IT IS SO ORDERED.