STIPULATION AND [PROPOSED] ORDER TO ENLARGE NON-EXPERT DISCOVERY DEADLINE

KANDIS A. WESTMORE, Magistrate Judge.

The United States of America and Lisa Zavieh, by and through undersigned counsel, hereby stipulate and request that the non-expert discovery deadline currently scheduled for July 6, 2018 be enlarged to August 6, 2018, and state as follows:

1. On January 25, 2018, the Court entered a Case Management and Pretrial Order for Bench Trial (Docket No. 46).

2. Per the Court's Order, non-expert discovery shall be completed by July 6, 2018 and expert discovery shall be completed by August 6, 2018 (Docket No. 46).

3. The United States believes that it will be necessary to depose Martin Lack, who advised Amir Zavieh regarding his Swiss bank account. Mr. Lack currently resides abroad, but is willing to voluntarily appear for a deposition to be taken in Washington, D.C.

4. To accommodate Mr. Lack and counsel for Ms. Zavieh's travel schedules, the United States requests that the non-expert discovery deadline be extended to August 6, 2018.

5. Undersigned counsel for the United States has conferred with undersigned counsel for Ms. Zavieh and Ms. Zavieh agrees to this request.

6. This is the parties' first stipulation for an extension of the non-expert discovery deadline.

WHEREFORE, the Parties hereby stipulate and request to enlarge the non-expert discovery deadline to August 6, 2018.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, and for good cause shown, IT IS HEREBY ORDERED that the non-expert discovery deadline is enlarged to August 6, 2018.

SO ORDERED.