STIPULATION RE FURTHER AMENDMENT OF SECOND PRETRIAL PREPARATION ORDER

SUSAN ILLSTON, District Judge.

Plaintiffs, L&M VENTURES, LLC, a California Limited Liability Company ("L&M"); STUART LERNER, an individual ("Lerner"); BLUE CHIP III, LLC ("BC-3"), Blue Chip II, LLC, a Mississippi limited liability company ("BC II"); Blue Chip Recycling, LLC, a California limited liability company ("BCR"), Defendant TRAVELERS CASUALTY & SURETY COMPANY OF AMERICA ("Travelers"), and Defendant LIPSCOMB & PITTS INSURANCE AGENCY, LLC ("Lipscomb"), by and through their attorneys of record, stipulate as follows:

1. The Court's Pretrial Preparation Order of September 9, 2015, provided for the following relevant deadlines and cut-off dates:

2. Following the parties unsuccessful mediation with Janet R. Fields, Esq. of Judicate West, on August 20, 2015, the Court, on September 11, 2015, ordered the parties to resume mediation in February 2016.

3. Upon plaintiffs' ex parte application, the Court, on November 17, 2015, issued an Order Extending the Time for Expert Witness Disclosures and Expert Discovery that amended the following dates:

a. Expert witness initial disclosures are extended from October 30, 2015, to November 30, 2015;

b. Expert witness rebuttal disclosures are extended from November 16, 2015, to December 16, 2015;

c. Expert discovery cut-off is extended from December 11, 2015, to January 11, 2016.

4. After the further case management conference was held in this action on December 18, 2015, and pursuant to the parties' request for an extension of certain deadlines in the Court's Pretrial Preparation Order, the Court entered a Second Pretrial Preparation Order on December 21, 2015 and continued the deadlines and dates in this action as follows:

5. The parties have exchanged written discovery, produced substantial documentation in response to requests for production, and deposed a majority of the parties' witnesses.

6. On February 18, 2016, after the parties participated in a lengthy second mediation with mediator Robert Kaplan, Esq. of Judicate West, Mr. Kaplan issued a settlement proposal to the parties. The parties have been provided with two weeks to respond to the settlement proposal due to the number of parties and complexity of issues involved in this action.

7. In order to provide the parties with sufficient time to (a) evaluate and respond to Mr. Kaplan's mediator's proposal, and (b) complete discovery, expert discovery, and accordingly file dispositive motions, and pursuant to the parties' request for an extension of certain deadlines in the Court's Pretrial Preparation Order, the Court entered an Order on the parties' Stipulation re Amendment of Second Pretrial Preparation Order on February 22, 2016 and continued the deadlines and dates in this action as follows:

8. Due to the complexity of issues in this case, the parties extended the deadline to respond to Mr. Kaplan's settlement proposal to March 18, 2016.

9. At this time, Mr. Kaplan continues to discuss settlement proposals with the parties. Nevertheless, the parties will proceed with completing discovery while such discussions are underway. As a result, the parties require additional time to complete discovery, expert discovery, and file dispositive motions. Accordingly, the parties agree that there is good cause to further amend the Second Pretrial Preparation Order to extend the deadlines and cut-offs as follows:

10. This stipulation may be signed in counterparts and electronic, photocopy and facsimile signatures will suffice as though they were original signatures.

IT IS SO ORDERED.