STIPULATION AND ORDER TO CONTINUE THE DEADLINE FOR DISCLOSURE OF EXPERTS AND DISCOVERY

JOHN A. MENDEZ, District Judge.

Plaintiff DR. GEORGE SAVAGE ("Plaintiff") and Defendants THE GOULD MEDICAL GROUP, INC. (incorrectly named as SUTTER GOULD MEDICAL GROUP), LESLIE D. SACKSCHEWSKY, M.D. and PATRICK L. SNYDER, M.D. (collectively, "Defendants"), by and through their counsel of record herein, herby stipulate and agree as follows:

WHEREAS, Plaintiff filed his operative Complaint against Defendants on December 20, 2013;

WHEREAS, on September 9, 2014, the parties stipulated, and the Court ordered, a continuance of deadlines and dates in the Pre-Trial Scheduling Order, including a continuance of the deadline to disclose expert witnesses to October 31, 2014, the discovery cut-off date to December 31, 2014 and the trial date to May 4, 2015;

WHEREAS, on September 29, 2014, following a Court order, Plaintiff provided an amended computation of damages which was substantially different than the previous version;

WHEREAS, Plaintiff was still providing documentation in support of his alleged damages in September 2014 and, based on the amended computation and documentation, Defendants believes additional information is required;

WHEREAS, the parties agree that additional discovery and investigation is needed in order to determine the experts they each must disclose, pursuant to Federal Rule of Civil Procedure 26(a)(2);

WHEREAS, due to scheduling complications for the depositions of the named defendants and other witnesses, Plaintiff believes that he needs additional time to complete the depositions.

WHEREAS, the parties agree that additional time is needed to complete the required depositions;

WHEREAS, the parties agree that there is good cause for a brief continuance of the deadlines related to expert disclosures and discovery, and that a continuance of these deadlines, and any other deadlines set in the Pre-Trial Scheduling Order, will not prejudice any party;

NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE that the time for disclosure of expert witness and reports in accordance with Federal Rule of Civil Procedure 26(a) is extended from October 31, 2014 to December 31, 2014; the disclosure of rebuttal experts is extended from November 7, 2014 to January 7, 2015; and the deadline for completing discovery is extended from December 31, 2014 to February 28, 2015.

THE PARTIES HEREBY FURTHER STIPULATE AND AGREE that the deadline for filing dispositive motions is extended from February 11, 2015 to April 8, 2015; the hearing on dispositive motions is continued from March 11, 2015 at 9:30 a.m. to May 6, 2015 at 9:30 a.m.; the deadline for filing the Joint Pre-Trial Statement is extended from March 20, 2015 to June 12, 2015; the Pre-Trial Conference is continued from March 27, 2015 at 11:00 a.m. to June 19, 2015 at 11 a.m.; and the Trial Date is continued from May 4, 2015 at 9:00 a.m. to August 3, 2015 at 9:00 a.m.

IT IS SO ORDERED.