STIPULATION TO AMEND THE SCHEDULING ORDER TO EXTEND EXPERT DISCOVERY

[ALL PARTIES REQUEST A JURY]

JOHN A. MENDEZ, District Judge.

COME NOW the Parties in this matter, and present this Stipulation for a Short Discovery Extension.

Plaintiffs, D.G., a minor, by and through his guardian ad litem, Denise Bonilla; D.E.G., a minor, by and through her guardian ad litem, Denise Bonilla; G.D., a minor, by and through her guardian ad litem, Denise Bonilla; and Ramona Ramirez Nunez, (hereinafter collectively "Plaintiffs") are jointly represented by Matthew C. Clark and Neil K. Gehlawat of Chain-Cohn-Stiles, and Dale K. Galipo of the Law Offices of Dale K. Galipo.

Defendants, County of Kern (hereinafter "County") and Deputy Robert Reed (hereinafter "Reed"), (hereinafter collectively "Defendants") are represented by Andrew C. Thomson and Kathleen Rivera, Office of Kern County Counsel.

Plaintiffs and Defendants are hereinafter collectively referred to as the "Parties." IT IS HEREBY STIPULATED AND AGREED TO, by and between the Parties, through their respective counsel of record, that an Order be entered modifying the Scheduling Order as follows: a) extend the Rule 26 Designation of Expert Witnesses to July 15, 2016; b) extend the Rule 26 Designation of Supplemental Experts to July 22, 2016; c) extend the expert discovery deadline to August 19, 2016; and d) maintaining the current "non-expert discovery" deadline of July 15, 2016.

1. Whereas, the Parties have repeatedly met and conferred regarding discovery and expert witness discovery issues in an effort to informally resolve discovery and expert issues, including deposition scheduling and designation concerns;

2. Whereas, the Parties continue to schedule the depositions of witnesses including the Coroner's Pathologist, the Kern County Sheriff's Office (hereinafter "KCSO") Public Information Officer, the Investigator Technicians, the KCSO Persons Most Knowledgeable in 21 separate categories, and other witnesses in conformance with the deadlines established by the Court in the Scheduling Order and Court's recent Order for a discovery extension, and with deadline of July 15, 2016 for all discovery;

3. Whereas, the Parties need deposition transcripts available for expert review and consideration prior to the experts preparation of their FRCP Rule 26 Reports;

4. Whereas, the Parties continue to diligently work together to coordinate deposition scheduling and prompt transcript preparation;

5. Whereas, in the spirit of civility, cooperation and good faith litigation, neither party has unilaterally scheduled depositions that are in conflict with the schedule of opposing counsel or the deponents;

6. Whereas, extension of the expert discovery deadlines are necessary as a result of the need to take the aforementioned depositions prior to designation of experts and to provide the experts the opportunity to review, analyze and consider the deposition testimony, the Parties are concerned that their experts will not have an opportunity to fully prepare expert reports.

7. Whereas, since the Parties would like to ensure that all experts have the opportunity to review, analyze and include all of the deposition information in their Rule 26 Expert Reports, the Parties request the following extensions:

8. Whereas, the Parties are informed and believe that the foregoing will not adversely affect the remainder of the dates set forth in the Scheduling Order, the Parties respectfully request the Court's consideration of this request.

THEREFORE, IT IS HEREBY STIPULATED THAT:

The Scheduling Order shall be amended to provide for the following deadlines extensions of two weeks:

IT IS SO ORDERED.