STIPULATION AND ORDER CONTINUING DEADLINE TO COMPLETE ALL DISCOVERY

JOHN A. MENDEZ, District Judge.

WHEREAS the court issued a scheduling order ("order") on or about May 16, 2013 (Doc. 30);

WHEREAS, pursuant to the order, the last day for the parties to exchange expert witness information is July 11, 2014 and supplemental disclosures and disclosure of any rebuttal experts under Fed. R. Civ. P. 26(a)(2)(c) must be made be made by July 25, 2014;

WHEREAS the last day for the parties to complete all discovery is September 12, 2014;

WHEREAS not later than fourteen (14) days prior to the close of discovery, the parties must file a "Joint Mid-Litigation Statements" summarizing all law and motion practice heard by the court, along with other information;

WHEREAS all dispositive motions shall be filed by October 22, 2014 and hearing on such motions shall be on November 19, 2014 at 9:30 a.m.;

WHEREAS the final pre-trial conference is set for January 16, 2015 at 11:00 a.m.;

WHEREAS this matter is presently set for trial on February 23, 2015 at 9:00 a.m.;

WHEREAS the parties have actively litigated this matter, including propounding and responding to written discovery, have taken depositions and have filed certain discovery motions;

WHEREAS the parties attended a private mediation before Judge Cecily Bond at JAMS on June 5, 2014 but did not resolve this matter;

WHEREAS the parties wish to take additional depositions;

WHEREAS Plaintiff's counsel will be unavailable during the month of July 2014 and Defendants have been on notice on such notice for a few months;

WHEREAS the parties may discuss resolution after the taking of additional depositions;

WHEREAS the parties wish to temporarily avoid incurring the expense of engaging in expert witness discovery, including depositions;

WHEREAS the parties have jointly agreed and stipulated to respectfully request that this Court grant an extension of time for the parties to complete discovery, excluding expert discovery, by October 13, 2014 and that the "Joint Mid-Litigation Statements" be filed fourteen (14) days prior to this new deadline by which to complete discovery, or October 13, 2014;

WHEREAS the parties have jointly agreed and stipulated to respectfully request that this Court grant an extension of time for the parties to complete expert discovery until after the filling and ruling on any dispositive motions (Oct. 22nd and Nov. 19, 2014), but before the final pre-trial conference set for January 16, 2015;

WHEREAS the parties request the court grant an extension to exchange expert witness information by December 10, 2014 and supplemental disclosures and disclosure of any rebuttal experts under Fed. R. Civ. P. 26(a)(2)(c) by January 7, 2015, and all expert witness depositions completed by January 15, 2015;

WHEREAS this request is not being made for the purpose of causing delay or for any other improper purpose;

WHEREAS continuing the above-referenced deadlines will not prejudice any party or their counsel; and

NOW, THEREFORE, IT IS HEREBY STIPULATED and agreed by Plaintiff and Defendants, through their respective attorneys of record, that this court continue the deadline for the parties to complete discovery by October 13, 2014, as set forth above, and expert discovery by January 15, 2015, as agreed upon and requested by the parties.

IT IS SO ORDERED.