STIPULATION REGARDING DEPOSITIONS;

ORDER THEREON

KENDALL J. NEWMAN, Magistrate Judge.

Plaintiff Dev Patel ("Plaintiff") and Defendants California Department of Public Health and Department of Toxic Substances Control (collectively, "Defendants"), through their respective counsel of record, hereby stipulate as follows:

WHEREAS counsel for Defendants took the deposition of Plaintiff on November 1, 2016 for approximately six hours;

WHEREAS Defendants requested at the outset of this case for an additional day for Plaintiff's deposition above the seven-hour limit imposed by Federal Rules of Civil Procedure, Rules 26(b)(2)(A) and 30(d)(1) due to the extensive factual allegations and claims at issue in this case, and the unusual volume of documentary evidence produced by the parties;

WHEREAS counsel for Plaintiff will have deposed a total of nine witnesses by June 20, 2017; and

WHEREAS Plaintiff requests to depose an additional eight witnesses (Brian Barrick, Monica Wilson-Pough, Kathleen Elizondo, Mandeep Sohi, Nicole Preston, Rebecca Vasquez, Joesette Rigby-Brokenbough, and Diana Guzman), exceeding the rule of ten depositions per side permitted by Federal Rules of Civil Procedure, Rules 26(b)(2)(A) and 30(a)(2)(A).

Consequently, Plaintiff and Defendants stipulate and agree as follows:

Plaintiff agrees to the requested additional time to depose Plaintiff, provided counsel for Defendants diligently uses reasonable efforts to conduct the deposition efficiently and agrees that Defendants will not request additional time to complete Plaintiff's deposition absent exceptional unforeseen circumstances; and

Defendants agree to the additional depositions enumerated above provided Plaintiff agrees to use reasonable efforts to conduct the depositions efficiently and agrees that Plaintiff will not request additional depositions absent exceptional unforeseen circumstances.

IT IS SO STIPULATED.

ORDER

Having reviewed the parties' stipulation, and good cause appearing therefore,

IT IS HEREBY ORDERED:

Defendants are permitted to take the deposition of Plaintiff for an additional seven hours beyond the limit imposed by Federal Rules of Civil Procedure, Rules 26(b)(2)(A) and 30(d)(1); and

Plaintiff is permitted to depose an additional eight witnesses (Brian Barrick, Monica Wilson-Pough, Kathleen Elizondo, Mandeep Sohi, Nicole Preston, Rebecca Vasquez, Joesette Rigby-Brokenbough, and Diana Guzman), exceeding the rule of ten depositions per side permitted by Federal Rules of Civil Procedure, Rules 26(b)(2)(A) and 30(a)(2)(A).