[Removed from Sacramento Superior Court, Case No. 34-2018-00240332-CU-WT-GDS]

JOINT STIPULATION TO EXTEND DISCOVERY DEADLINES; ORDER

TROY L. NUNLEY, District Judge.

Plaintiff MIKHAIL NATYAZHKO ("Plaintiff") and Defendant WALMART INC. ("Defendant"), by and through their counsel of record, hereby jointly stipulate and respectfully request that the Court extend the fact discovery deadline from July 24, 2019 to September 5, 2019, expert disclosures to September 26, 2019, and supplemental expert disclosures to October 17, 2019.

In support of this stipulation, the parties state as follows:

WHEREAS, this Court entered its initial Pretrial Scheduling Order ("Scheduling Order") on October 12, 2018;

WHEREAS, Plaintiff's deposition was scheduled for May 28, 2019 but the deposition has been rescheduled due to Plaintiff's health condition;

WHEREAS, the parties have agreed that Plaintiff's deposition will proceed on August 20, 2019;

WHEREAS, Plaintiff has also scheduled the depositions of other fact witnesses for August 14, 2019;

WHEREAS, the parties have scheduled a mediation with attorney Mark Peters for August 27, 2019;

WHEREAS, based on the progress of this case, an extension of the deadlines for completing fact discovery will allow the Parties to finalize their discovery and to adequately try to resolve this matter free of further litigation;

WHEREAS, only a brief 45-day extension of the fact discovery cut-off has previously been sought by the Parties;

WHEREAS, no trial date has been set and the proposed extension of the deadlines for completing fact discovery will not delay or prejudice the timely resolution of this case;

WHEREAS, Federal Rule of Civil Procedure 16(b)(4) requires good cause and judicial consent as prerequisites to modifying a scheduling order; and

THEREFORE, THE PARTIES HEREBY STIPULATE to, and seek an order from this Court permitting the following new deadlines:

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.