STIPULATION AND [ PROPOSED ] ORDER TO MODIFY SCHEDULING ORDER

ALLISON CLAIRE, Magistrate Judge.

Pursuant to Rule 16(b) of the Federal Rules of Civil Procedure, Local Rules 240 and 270, and the Court's Pretrial Scheduling Order, Plaintiff Jose Aranda and Defendant American Pasteurization Company ("Defendant" or "APC") (collectively the "Parties") hereby submit this Stipulation and [Proposed] Order to Modify the Pretrial Scheduling Order. The Parties request that the Court modify the Pretrial Scheduling Order and continue the expert witness disclosure dates by five (5) months as set forth below.

IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES TO THIS ACTION, through their counsel of record, as follows:

1. WHEREAS, on January 24, 2017, this Court issued a Pretrial Scheduling Order (the "Scheduling Order") in this matter.

2. WHEREAS, pursuant to the Scheduling Order, the deadline for expert witness disclosures is July 28, 2017, and the deadline for rebuttal expert witness disclosures is August 31, 2017.

3. WHEREAS, the Parties' deadline to file and serve motions is November 20, 2017.

4. WHEREAS, the Parties anticipate mediating this case in the summer of 2017, and agree that mediation may resolve some or all of the claims at issue in this case.

5. WHEREAS, if mediation is unsuccessful in resolving the case in its entirety, Defendant intends to file a dispositive motion on or before the November 20, 2017 deadline, which may dispose of the case or narrow the issues to be addressed at trial.

6. WHEREAS, both parties wish to avoid the incurrence of expert witness fees and costs (or rebuttal witness fees and costs), as well as associated written discovery, depositions, and meet and confer efforts, if some or all of the case may be disposed of via settlement or other means.

7. WHEREAS, the Parties have met and conferred, and now agree that it is in the best interest of economic and judicial efficiency to continue the expert witness disclosure dates by five (5) months, until after mediation can be completed and summary judgment can be decided.

8. WHEREAS, the Parties further agree that good cause exists to continue the expert witness disclosure deadlines, as a continuance is needed to prevent the expenditure of time and resources on experts that may not be needed for trial.

NOW THEREFORE, the Parties hereto stipulate and agree that the Court may enter an Order continuing the July 28, 2017 and August 31, 2017 expert witness disclosure deadlines as follows:

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

ATTESTATION PURSUANT TO LOCAL RULE 131

Pursuant to Local Rule 131, I, Pamela Vartabedian, hereby attest that the content of this document is acceptable to Linh T. Nguyen, Counsel for Plaintiff Jose Aranda, and that I have obtained Mr. Nguyen's authorization to affix his electronic signature to this document.

Executed this 16th day of February 2017 in San Francisco, CA.

PURSUANT TO STIPULATION, IT IS SO ORDERED:

The expert witness disclosure deadlines will be continued as follows: