STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF

WILLIAM H. ORRICK, District Judge.

STIPULATION

Defendant SANTA ROSA CITY SCHOOLS (the "DISTRICT") and plaintiff JANE DOE NO. 59 by and through their respective attorneys of record, hereby stipulate as follows:

1. The Court originally assigned a Fact Discovery cutoff date of February 14, 2017. The Parties requested additional time to complete discovery on February 13, 2017. The Court granted the parties proposed stipulated Fact Discovery cutoff date of April 10, 2017.

2. Both parties require additional time to complete discovery. Trial is set for August 14, 2017.

3. The DISTRICT intends to conduct the following further discovery: (1) depose the officers involved in the incident. DOE intends to conduct the following further discovery: (1) depose Defendant's District Representative(s) in accordance with Rule 30(b)(6), and (2) depose Lindsey Apkarian.

4. The parties therefore respectfully request that the Court extend the Fact Discovery cutoff date 14 days to April 24, 2017. This extension will not affect the trial date or any other dates previously set by the Court. The parties' stipulation of extending the Fact Discovery cutoff is contingent on such an extension not affecting the trial date.

5. Further, Defendant's expert is unable to provide a written report until April 28, 2017. The parties respectfully request that the Court extend the Expert Discovery deadlines 14 days as follows: (1) Expert Disclosure: April 28, 2017. This extension will not affect the trial date or any other dates previously set by the Court. In fact, the parties' stipulation of extending the Discovery cutoff is contingent on such an extension not affecting the trial date.

10. The parties respectfully request that the Court approve this stipulation and incorporate its terms in an Order.

ATTORNEY ATTESTATION

I hereby attest that I have on file all holograph signatures for any signatures indicated by a conformed signature ("/s/") within this E-filed document or have been authorized by all parties to show their signature on this document as/s/.

ORDER

GOOD CAUSE APPEARING THEREFORE, and the parties' having stipulated to the same, the parties' stipulation is hereby APPROVED. The Fact Discovery cutoff currently set for April 10, 2017 is continued 14 days to April 24, 2017. This extension will not alter or affect the trial date or any other dates previously set by the Court.

Expert Discovery deadlines are continued 14 days as follows: (1) Expert Disclosure: April 28, 2017. This extension will not affect the trial date or any other dates previously set by the Court.

IT IS SO ORDERED.