STIPULATION AND ORDER MODIFYING CASE MANAGEMENT DEADLINES

EDWARD J. DAVILA, District Judge.

WHEREAS, the Court entered a Case Management Order on October 1, 2013 (Dkt. #49);

WHEREAS, the Parties filed their respective pleadings regarding Plaintiff's Second Motion for Class Certification (Dkt. #50) ("Class Certification motion");

WHEREAS, the Clerk gave the Parties notice that the Court has taken the Class Certification motion under submission without oral argument pursuant to Civ. L. R.7-1(b) (Dkt. #67);

WHEREAS, the Court entered an Order Modifying Case Management Deadlines on March 10, 2014 (Dkt. #69);

WHEREAS, Defendant filed a Motion for Partial Summary Judgment (Dkt. #55), and the Clerk gave the Parties notice that the Court has taken the Summary Judgment motion under submission without oral argument pursuant to Civ. L. R. 7-1(b);

WHEREAS, to date, the Parties have completed substantial written and deposition factual discovery, as well as limited expert discovery on Plaintiff's theory of class remedies in connection with her class certification motion. However, the Parties submit that, in the interests of efficiency, further discovery should be completed following the ruling on Plaintiff's Class Certification motion and Defendant's summary judgment motion. In that regard, the Parties believe that the Court's rulings on those motions will give the Parties substantial guidance as to the issues remaining in dispute and the evidence that will be necessary to present at the time of trial or in connection with any further dispositive motions. Similarly, the Parties submit that they are unable to designate all of their respective expert witnesses or complete all expert witness reports and conduct expert depositions until the Court rules on the Plaintiff's Class Certification motion and the Summary Judgment motion.

THEREFORE, the Parties stipulate and agree to the following, subject to Court approval:

(1) That the current deadlines set for expert disclosures and reports, for the close of discovery, and for dispositive motions, be amended as follows:

(2) That all fact discovery shall be COMPLETED by no later than 90 days after the Court's decision on the later of the Class Certification motion or the Summary Judgment motion;

(3) That Plaintiff's expert reports shall be due by no later than 120 days after the Court's decision on the later of the Class Certification motion or the Summary Judgment motion;

(4) That Defendant's expert reports shall be due by no later than 60 days after the deadline for Plaintiff's expert reports;

(5) That Plaintiff's rebuttal expert reports shall be due by no later than 30 days after Defendant's expert reports;

(6) That expert discovery shall be COMPLETED by no later than 240 days after the Court's decision on the later of the Class Certification motion or the Summary Judgment motion;

(7) That any further dispositive motions shall be filed by no later than 14 days after the close of expert discovery.

(8) In the event that any of the above-listed deadlines shall fall on a weekend or Court holiday, the effective deadline shall be the next business day.

PURSUANT TO THE PATRIES' STIPULATION, IT IS SO ORDERED.