STIPULATION TO CONTINUE EXPERT DISCOVERY CUTOFF AND PLAINTIFF'S MOTION TO COMPEL SUPPLEMENTAL DISCOVERY RESPONSES DEADLINE; ORDER

MICHAEL J. SENG, Magistrate Judge.

DeVry University ("Defendant") and Lorena Lopez ("Plaintiff") (collectively referred to herein as the "Parties"), by and through their undersigned counsel, hereby stipulate and agree as follows:

1. WHEREAS, the deadline to complete expert discovery is July 7, 2014.

2. WHEREAS, the deadline to file discovery motions is July 7, 2014.

3. WHEREAS, the Parties have worked diligently to coordinate and schedule the depositions of two non-retained healthcare providers of Plaintiff identified in Plaintiff's Expert Witness Disclosure, Isabel C. Amancio, LMFT, 113 Church Street, #418, Visalia, California, and Shyam Bhaskar, MD, 231, W. Noble Avenue, Visalia, California 93277;

4. WHEREAS, Defendant served subpoenas for deposition testimony and production of documents on Ms. Amancio and Dr. Bhaskar for late June 2014 depositions;

5. WHEREAS, Dr. Bhaskar advised the Parties that he was completely unavailable prior to this time and, further, that he would out of the country until August 2014.

6. WHEREAS, the Parties further believe that the most cost efficient approach to expert depositions in this case would be to take both in a single day, particularly because of Defendant's need to travel from Sacramento to Visalia;

7. WHEREAS, the Parties have also worked diligently to meet and confer on written discovery propounded by Plaintiff, including two sets of requests for production of documents and interrogatories. Defendant anticipates supplemental responses will be served by July 15, 2014 and thereafter Plaintiff will need additional time to review and determine if a motion to compel further responses is necessary.

8. WHEREAS, the parties have agreed that discovery shall remain open to September 8, 2014 only for the following: (1) Defendant to depose Plaintiff's healthcare experts Shyam Bhaskar, M.D. and Isabel Amancio, MFT; and (2) Defendant to prepare and serve supplemental discovery responses (per Plaintiff's February 3, 2014 and Defendant's February 21, 2014 meet and confer correspondence), and Plaintiff to move to compel such supplemental responses if necessary.

9. WHEREAS, extending the deadline for expert discovery and Plaintiff's motion to compel supplemental written discovery responses will not result in a change to subsequent deadlines regarding the January 6, 2015 trial date.

NOW THEREFORE, all Parties hereto stipulate and agree that the Court may enter an Order extending discovery to September 8, 2014 for: (1) Defendant to depose Plaintiff's healthcare experts Shyam Bhaskar, M.D. and Isabel Amancio, MFT; and (2) Defendant to prepare and serve supplemental discovery responses (per Plaintiff's February 3, 2014 and Defendant's February 21, 2014 meet and confer correspondence) and Plaintiff to move to compel such supplemental responses if necessary. Plaintiff reserves the right to file a motion and seek leave for additional discovery subject to the Court's approval and good cause shown.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

ORDER

Good cause appearing, the above Stipulation is accepted and adopted as the Order of this Court.

IT IS SO ORDERED.