STIPULATION FOR EXTENSION OF DISCOVERY

SUSAN Y. ILLSTON, District Judge.

Pursuant to Local Rules 6-1 and 6-2, the parties through undersigned counsel hereby stipulate and respectfully request that the Court extend the deadline for Non-Expert Discovery and other pre-trial dates. The parties declare in support of this request:

WHEREAS, on July 28, 2014, the Court ordered that the Non-Expert Discovery Cutoff would be December 5, 2014 (Dckt. No. 39);

WHEREAS, on October 20, 2014, Plaintiffs submitted a letter to the Court summarizing its discovery dispute with Defendants (Dckt. No. 40);

WHEREAS, on October 29, 2014, the Court issued an order directing Defendants to produce requested electronic accounting files to Plaintiffs no later than November 3, 2014 (Dckt. No. 41);

WHEREAS, on November 7, 2014, Plaintiffs submitted a second letter to the Court summarizing its ongoing discovery dispute with Defendants (Dckt. No. 42);

WHEREAS, on November 12, 2014, the Court issued an order directing Defendants to produce requested electronic accounting files that can be opened to Plaintiffs no later than November 14, 2014 (Dckt. No. 44);

WHEREAS, as of November 14, 2014, Defendants have provided Plaintiffs with a username and password, but Plaintiffs continue to experience technical issues accessing the requested electronic accounting files, and are working with Defendants to resolve these issues;

WHEREAS, Plaintiffs require additional time to conduct a meaningful review of said electronic accounting files, so that depositions may be constructive;

WHEREAS, Plaintiffs would like the opportunity to complete mediation efforts with Defendants once said electronic accounting files have been reviewed;

THEREFORE, pursuant to Local Rule 6-2, the parties though their respective attorneys stipulate as follows:

The parties respectfully request that the Court extend the Non-Expert Discovery Cutoff date to February 20, 2015.

The requested time modification will affect the schedule for the case by necessitating that the following dates be likewise moved:

If the proposed pre-trial dates are unavailable, the parties are agreeable to alternative dates that the Court may schedule.

IT IS SO STIPULATED AND AGREED.

[PROPOSED] ORDER GRANTING STIPULATION FOR EXTENSION OF DISCOVERY

Having considered the parties' Stipulation for Extension of Discovery, and for good cause shown,

PURSUANT TO STIPULATION, As amended IT IS HEREBY ORDERED that the Non-Expert Discovery Cutoff date is now set for February 20, 2015. Likewise, the following pre-trial dates are now set for: