STIPULATION AND [PROPOSED] ORDER TO PARTIALLY REVISE THE COURT'S SCHEDULING ORDER

JON S. TIGAR, District Judge.

Plaintiff Jason-Issa Karkar and Defendant State Farm General Insurance Company ("State Farm"), by and through their respective counsel, hereby stipulate to revise the Court's March 12, 2015 Revised Scheduling Order (Dkt 28) and to revise the briefing schedule for State Farm's motion for summary judgment as follows:

I.

RECITALS

1. The parties have been working diligently toward moving this case forward in an efficient and expeditious manner. Despite the parties' diligent efforts and cooperation to complete discovery, the parties seek a short continuance of the fact and expert deadlines and a revised briefing schedule for State Farm's summary judgment motion. The parties do not seek to continue the pre-trial dates or the trial date.

2. On March 12, 2015, pursuant to the parties' stipulation, the court revised the scheduling order with regards to the fact and expert discovery deadlines, and the trial date. [Docket Number 28];

3. Since the revised scheduling order was entered, the parties have diligently worked on completing discovery, including scheduling numerous deposition of key witnesses and conducting further written discovery.

4. On June 12, 2015, State Farm filed its motion for summary judgment, which will be heard on July 23, 2015. Presently, plaintiff's opposition papers are due June 26, 2015 and State Farm's reply brief is due July 6, 2015. The parties agree to give plaintiff additional time to file his opposition brief, and agree that plaintiff's opposition brief will be due July 2, 2015. The parties agree that State Farm's reply brief will be due July 9, 2015, a week after plaintiff's opposition is filed.

5. The parties seek a short continuance of the fact discovery cut-off date to June 30, 2015.

6. The parties seek a short continuance of the expert deadlines to avoid the time and expense of disclosing and deposing experts until after a ruling on the summary judgment motion.

7. The parties have agreed to a proposed stipulated order revising the scheduling order and the briefing schedule for State Farm's summary judgment motion as follows:

II.

STIPULATION

For the reasons set forth above, the parties hereby stipulate to the following revisions to the court's Pretrial Schedule:

[PROPOSED] ORDER

Pursuant to the parties' stipulation, the Pretrial Schedule is revised as follows: