STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE FOR MEDIATION

KANDIS A. WESTMORE, Magistrate Judge.

Plaintiff, Ruben Sumera, and Defendant, Eric H. Holder, Jr., Attorney General, U.S. Department of Justice, in his official capacity, hereby stipulate as follows, subject to the approval of the Court:

1. On February 4, 2015, the parties submitted a stipulation reflecting their agreement to participate in mediation. ECF No. 49. On February 5, 2015, the Court adopted and so ordered the parties' stipulation to hold the mediation by 120 days from the date of the order, or by June 5, 2015. ECF No. 50. On March 2, 2015, the Notice of Appointment of Mediator Richard Whitmore was filed. ECF No. 52.

2. The parties through their counsel participated in a teleconference with the mediator on March 10, 2015, to discuss mediation procedures and scheduling matters. Immediately prior to this teleconference, counsel conferred and agreed that it would be preferable to extend the current deadline for completion of the mediation in order to permit the parties to resolve discovery issues and complete certain depositions.

3. Specifically, Defendant will be deposing Plaintiff on April 30, 2015. Plaintiff has also requested to take the depositions of two of his former supervisors. The parties are working on scheduling these two depositions, one of which will likely require travel to Washington, D.C. Due to counsel's scheduling commitments, including trial dates in another case, it is possible that these depositions may not occur until late June.

4. The parties discussed these discovery and scheduling issues with the mediator and agreed that it would allow for a more meaningful mediation if the parties were to seek a 90-day extension of the current mediation deadline. Mediator Whitmore has indicated that he does not have any objection to this requested extension.

5. The requested extension will not interfere with the rest of the case management schedule. The fact discovery cut-off date is September 7, 2015, and the trial date is January 25, 2016.

6. The parties respectfully request that the Court permit this requested extension and so indicate by signing the proposed order below, thereby extending the current deadline for completion of the mediation by 90 days to September 4, 2015.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

PURSUANT TO STIPULATION, IT IS SO ORDERED. The deadline for completing the mediation is extended to September 4, 2015.