JOINT STIPULATION FOR CONTINUANCE OF CERTAIN PRE-TRIAL DATES; [PROPOSED] ORDER

SAUNDRA BROWN ARMSTRONG, District Judge.

WHEREAS, the court in each of the three above-captioned related actions —Valdez, et al. v. The Travelers Indemnity Company of Connecticut, et al., United States District Court for the Northern District of California, Case No. 12-cv-4307-SBA, Ernst v. The Travelers Indemnity Company of Connecticut, et al., United States District Court for the Northern District of California, Case No. 13-cv-0463-SBA, and Ernst, et al. v. The Travelers Indemnity Company of Connecticut, et al., United States District Court for the Northern District of California, Case No. 13-cv-0464-SBA — through its Order for Pretrial Preparation issued on June 27, 2013 (ECF 44), Order for Pretrial Preparation issued on June 27, 2013 (ECF 23), and Consolidated Order for Pretrial Preparation issued on October 28, 2013 (ECF 16), respectively, set the following deadlines, among others:

• Expert discovery completion: January 24, 2013

WHEREAS, the parties continue to be engaged in discovery, and need to take numerous additional depositions, some of which pertain to all three related actions;

WHEREAS, based on the discovery to date, and in part to potentially avoid the necessity of taking many of the numerous additional depositions, the parties to the above-captioned Valdez, et al. v. The Travelers Indemnity Company of Connecticut, et al. action have agreed to participate in a mediation on November 19, 2013 with Hon. Jack Komar (Ret.), and the plaintiffs in the related Ernst, et al. v. The Travelers Indemnity Company of Connecticut, et al. actions may also participate in that mediation or a separate mediation with The Travelers Indemnity Company of Connecticut;

WHEREAS, the parties wish to postpone most or all of the depositions until after the mediation, such that those depositions are only necessary if the cases do not resolve by mediation;

WHEREAS, the parties agree that the pretrial deadlines identified herein should be continued by approximately thirty days in order to allow the parties to postpone most or all of the depositions until after mediation;

WHEREAS, the parties are not seeking a continuance of the trial dates in the above-captioned actions, which trial dates are May 12, 2013, May 12, 2013, and May 28, 2013, respectively;

WHEREAS, the parties are only seeking a continuance of those dates identified below;

STIPULATION

NOW THEREFORE, it is agreed and stipulated by and between:

1. Defendants The Travelers Indemnity Company of Connecticut (also erroneously sued as The Travelers Insurance Company1), The Travelers Indemnity Company, and Travelers Property and Casualty Company of America (collectively, "Travelers"), by and through its counsel of record Benjamin E. Shiftan of Sedgwick LLP;

2. Plaintiffs Ulises Valdez and Valdez & Sons Vineyard Management, by and through their counsel of record Matthew R. Lilligren of Abbey, Weitzenberg, Warren & Emery;

3. Plaintiffs William Ernst and Debra Ernst, by and through their counsel of record Peter L. Simon, of Beyers Costin, P.C., that:

The following dates previously set by order of the Court be continued and modified in each of the above-captioned actions as follows:

• The deadline for completing non-expert discovery shall be continued from December 20, 2013 to January 20, 2013.

IT IS SO STIPULATED.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.