JOINT STIPULATION TO EXTEND TIME PURSUANT TO FED. R. CIV. P. 30(e) TO REVIEW DEPOSITION TRANSCRIPT and [Proposed] ORDER PURSUANT TO EASTERN DISTRICT LOCAL RULE 144 The

EDMUND F. BRENNAN, District Judge.

Whereas the continuation of Charging Party Homeyra Kazerounian's deposition took place on June 13, 2014;

Whereas Plaintiff EEOC received a copy of Ms. Kazerounian's deposition transcript on June 24, 2014 and Ms. Kazerounian has thirty days from this date to review her deposition transcript pursuant to Federal Rule of Civil Procedure 30(e);

Whereas Plaintiff's counsel, Debra A. Smith, was on family medical leave in Florida from June 14 through June 28, 2014;

Whereas Plaintiff EEOC inadvertently failed to provide a copy of Ms. Kazerounian's transcript to her during Ms. Smith's absence;

Whereas Ms. Smith was unaware that a copy of Ms. Kazerounian's transcript had not been mailed to Ms. Kazerounian while Ms. Smith was on leave;

Whereas Ms. Smith first learned that Ms. Kazerounian did not receive a copy of her transcript until July 10, 2014 when she was anticipating receiving any corrections Ms. Kazerounian may have made;

Whereas Ms. Smith is scheduled to take another two week medical leave of absence beginning July 14 through July 28, 2014;

Whereas it would be extremely difficult for Ms. Kazerounian to review her 285 page deposition transcript in English within the next few days before Ms. Smith goes on leave; and

Whereas Plaintiff EEOC and Defendant Placer ARC d/b/a Placer Advocacy, Resources and Choices (Placer ARC) both agree that an extension of the Fed. R. Fed. P. 30(e) thirty day deadline though August 15, 2014, approximately three additional weeks, would allow Ms. Kazerounian sufficient time to review her deposition and Ms. Smith sufficient time to review any changes Ms. Kazerounian may make without imposing any undue burden on any of the parties, it is therefore:

STIPULATED by and between the undersigned counsel that, pursuant to Rule 30(e) of the Federal Rules of Civil Procedure and Local Rule 144(a) of the Eastern District of California, Ms.JOINT STIPULATION TO EXTEND TIME Kazerounian be given additional time through August 15, 2014 to review and identify any changes that may be needed to correct her deposition testimony of June 13, 2014.

IT IS SO ORDERED.