STIPULATION AND ORDER EXTENDING THE DEADLINE TO COMPLETE DISCOVERY

WILLIAM B. SHUBB, District Judge.

Plaintiff Hany Nasrallah, and Defendants Kaplan, Inc., Kaplan Higher Education, LLC, and Kaplan Higher Education Corporation (collectively, the "Parties"), through their respective counsel, hereby submit the following stipulation:

WHEREAS, the Court set this matter for trial on November 15, 2016 in its Pre-Trial Scheduling Order of August 18, 2015 ("Scheduling Order") (ECF No. 8);

WHEREAS, the Scheduling Order provides that all discovery, including depositions, must be completed no later than May 31, 2016;

WHEREAS, the Scheduling Order defined "completed" to mean that "all discovery shall have been conducted so that all depositions have been taken and any disputes relevant to discovery shall have been resolved by appropriate order if necessary and, where discovery has been ordered, the order has been obeyed";

WHEREAS, the Parties have exchanged an initial round of written discovery, and are in the process of meeting and conferring regarding their respective responses;

WHEREAS, Defendant Kaplan Higher Education, LLC ("KHE") took the deposition of Plaintiff Hany Nasrallah ("Plaintiff") on March 14, 2016;

WHEREAS, Plaintiff's deposition was the first deposition taken in this action, and the Parties are meeting and conferring for the purpose of scheduling the depositions of other witnesses with knowledge of facts relevant to this litigation;

WHEREAS, the Parties agree that additional time will be necessary to propound further written discovery and to complete the above-referenced depositions.

NOW, THEREFORE, the Parties hereby stipulate and agree as follows:

1. The deadline to complete all discovery, currently May 31, 2016, shall be extended to August 31, 2016. "Complete," as used in this Stipulation, shall have the same definition as set forth in the Court's Scheduling Order.

2. All motions to compel discovery must be noticed on the magistrate judge's calendar in accordance with the Eastern District of California's local rules, such that any such motions may be heard (and any resulting orders obeyed) not later than August 31, 2016.

ORDER

Upon consideration of the Stipulation Extending the Deadline to Complete Discovery, jointly submitted by Plaintiff Hany Nasrallah, and Defendants Kaplan, Inc., Kaplan Higher Education, LLC, and Kaplan Higher Education Corporation, and for good cause shown, the Court hereby ORDERS as follows:

1. The deadline to complete all discovery, currently May 31, 2016, is hereby extended to August 31, 2016. "Complete," as used in this order, shall have the same definition as set forth in the Court's Scheduling Order (ECF No. 8).

2. All motions to compel discovery must be noticed on the magistrate judge's calendar in accordance with the Eastern District of California's local rules, such that any such motions may be heard (and any resulting orders obeyed) not later than August 31, 2016.

IT IS SO ORDERED.