JOINT STIPULATION TO EXTEND MEDIATION DEADLINE FROM OCTOBER 15, 2016, TO NOVEMBER 30, 2016; AND

[PROPOSED] ORDER.

JON S. TIGAR, District Judge.

Intuitive Surgical, Inc. ("Intuitive") and Illinois Union Insurance Company ("Illinois Union") jointly stipulate, pursuant to Civil Local Rules 6-1(b), 6-2, and 7-12, to extend the deadline for mediation of the consolidated actions numbered Case No. 3:13-cv-04863-JST and Case No. 3:15-cv-04834-JST, if it pleases this Court.

WHEREAS, on July 26, 2016, the parties submitted a Joint Stipulation to Scheduling Order which was approved and entered by the Court on July 28, 2016 (Dkt. 1861).

WHEREAS, the Scheduling Order provided for a mediation deadline of October 15, 2016.

WHEREAS, the parties have been conducting fact discovery in Case No. 3:15-cv-04834-JST, which has a fact discovery cut-off date of November 10, 2016.

WHEREAS, the parties through their counsel have met and conferred, and agree that a private mediation is best conducted after the close of all fact discovery on November 10, 2016.

NOW THEREFORE, the parties, through the undersigned counsel, hereby respectfully stipulate and request that this Court extend the mediation deadline to November 30, 2016, to allow the parties adequate time to conduct a private mediation in consolidated actions numbered Case No. 3:13-cv-04863-JST and Case No. 3:15-cv-04834-JST, if this date is convenient to this Court. This change in the deadline for mediation will not change or affect any of the other dates in the Scheduling Order entered on July 28, 2016:

Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the filing of this document has been obtained from the signatories above.

[PROPOSED] ORDER

PURSUANT TO THE FOREGOING STIPULATION OF THE PARTIES, IT IS ORDERED THAT:

The Court enters the following modification to the case schedule for consolidated actions numbered Case No. 3:13-cv-04863-JST and Case No. 3:15-cv-04834-JST: