STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES FOR DISCOVERY AND DISCLOSURES OF EXPERT WITNESSES

DONNA M. RYA, Magistrate Judge.

The parties, plaintiff, Deborah Santana-Watts, and defendants, Admiral Line Limited and Zodiac Maritime Agencies Limited, by and through their counsel of record, submit this stipulation and proposed order to extend the discovery deadline and the date to disclose expert witnesses and reports. The stipulation and request for an order are based upon the following:

1. Currently, September 24, 2013, is the date that the Court set for the close of non-expert discovery and for the disclosure of expert witnesses and reports.

2. The parties recently participated in a mediation session with Jonathan D. Schmidt, who at the time of his appointment as the Northern District ADR panel mediator in this case was an Assistant U.S. Attorney for the Northern District of California. The parties made substantial progress at the mediation session, exchanging numerous offers and counter-offers, but the case did not settle. Mr. Schmidt has scheduled a follow-up conference call to continue negotiations for October 7, 2013.

3. Prior to the deadline for non-expert discovery, the defendants noticed the depositions of two potential longshore witnesses and the plaintiff requested an inspection of the vessel on which plaintiff's accident occurred. The parties agreed to postpone the depositions until a time following the mediation session and for a time that the schedule of plaintiff's counsel could accommodate. As to the vessel inspection, counsel for the defendants has ascertained that the vessel is currently at sea, sailing between ports in the Far East. It is not currently scheduled to call at the Port of Oakland, but is scheduled to call at the Port of Tacoma, Washington, on or about October 21, 2013. Although the defendants are in a position to disclose experts and produce reports by the current deadline, the plaintiff will not be in that position until the planned vessel inspection can be completed.

4. Under the circumstances, the parties request that the non-expert discovery deadline and the date for expert disclosures and reports be extended until October 31, 2013.

5. Neither party intends to file a dispositive motion. Thus, the only other currently scheduled deadlines that would be affected by this request are those relating to the disclosure of rebuttal expert witnesses and the depositions of expert witnesses. The parties request that those deadlines, which are currently set for October 8, 2013 and October 22, 2013, respectively, be extended to November 15, 2013 and November 30, 2013, respectively.

6. These extensions will give the parties the further opportunity to fully explore settlement opportunities prior to their beginning of their preparation for trial.

THE PARTIES SO STIPULATE.

ORDER

Pursuant to the foregoing stipulation, the Court GRANTS the parties' request and extends the non-expert discovery deadline and the date for expert disclosures and reports until October 31, 2013. In addition, the Court extends the deadlines for the disclosure of rebuttal expert witnesses and the depositions of expert witnesses to November 15, 2013 and November 30, 2013, respectively.

IT IS SO ORDERED.