STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF EXPERT DISCOVERY DEADLINE

RICHARD SEEBORG, District Judge.

Defendant Stonebridge Life Insurance Company ("Stonebridge") and Plaintiff Jessica Lee (collectively with Stonebridge, the "Parties," each a "Party"), by and through their respective counsel of record, hereby enter into the following stipulation:

WHEREAS, on May 28, 2013, the Court entered an order setting the deadline for completion of all expert discovery for September 27, 2013. (ECF No. 112.)

WHEREAS, on August 8, 2013, the Parties exchanged Rule 26(a)(2) expert reports; WHEREAS, on September 6, 2013, the Parties exchanged rebuttal expert reports;

WHEREAS, the Parties have propounded written discovery requests on experts, and the experts have responded to such requests;

WHEREAS, as a result of scheduling conflicts, the Parties have been unable to schedule expert depositions for mutually convenient times prior to the current September 27 deadline;

WHEREAS, the Parties have agreed to schedule the depositions of two experts on October 3, 2013, and October 4, 2013;

WHEREAS, the Parties expect to reach agreement on the schedule for the remaining expert depositions shortly;

WHEREAS, this case is not set for trial until June 23, 2014, and a short extension of the deadline for completion of expert discovery should not impact other case deadlines;

THEREFORE, subject to the approval of the Court, the Parties agree and stipulate as follows:

1. The deadline for completion of expert discovery is extended from September 27, 2013 to October 25, 2013.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED