STIPULATION AND ORDER TO EXTEND DEADLINES

EDWARD M. CHEN, District Judge.

Defendants the United States Environmental Protection Agency and Administrator Andrew Wheeler,1 in his official capacity, (collectively the "EPA") and Plaintiffs (collectively the "parties") stipulate as follows:

WHEREAS, on June 27, 2019, pursuant to the Stipulation on Discovery Schedule Order ("Discovery Schedule Order," ECF No. 98), the parties served opening Expert Designations and Disclosures. Plaintiffs disclosed five "retained" experts and two "non-retained" experts. EPA disclosed two "retained" experts and one "non-retained" expert.

WHEREAS, on August 1, 2019, pursuant to the Discovery Schedule Order, the parties served rebuttal Expert Designations and Disclosures. EPA disclosed two additional "retained" experts.

WHEREAS, the parties conferred extensively in a good faith attempt to make each of the twelve experts available for deposition prior to the existing expert discovery deadline, but were unable to do so. Under the existing agreed-upon deposition schedule among the parties, the last deposition is scheduled for September 18, 2019. Thus, the parties propose and stipulate that the expert discovery cut-off be extended 13 days, from September 5, 2019 to September 18, 2019.

WHEREAS, consequently, the parties also propose and stipulate that the deadlines for dispositive motions be extended a commensurate two weeks, from September 19, 2019 to October 3, 2019.

WHEREAS, consequently, pursuant to local rule 7-2(a), the parties propose and stipulate that the deadline for the last day to be heard on motions for summary judgment be extended a commensurate two weeks, from October 24, 2019 to November 7, 2019.

WHEREAS, the parties have been working cooperatively to address certain discovery disputes in good faith not to disrupt the proposed expert discovery schedule. Thus, the parties stipulate that these proposed extensions should not change or alter the Trial Date currently set for February 3, 2020.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the parties:

1. The parties represent that they have met and conferred extensively and in good faith to schedule depositions for expert witnesses within the time allotted for expert discovery.

2. Good cause exists to extend deadlines to accommodate the expert deposition schedule agreed upon by the parties.

3. The expert discovery cut-off date is September 18, 2019.

4. The last day to file dispositive motions is October 3, 2019.

5. The last day to be heard regarding dispositive motions is November 7, 2019.

6. The Trial Date currently set for February 3, 2020, shall not change.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.