STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY DEADLINES

KENDALL J. NEWMAN, Magistrate Judge.

Plaintiffs TAT Tohumculuk A.S. ("Plaintiff") and Defendants H.J. Heinz Company, L.P., and Heinzseed, an unincorporated division of H.J. Heinz Company, L.P. (collectively, "Defendants") (collectively, the "Parties") hereby submit, through their undersigned counsel of record, the following Stipulation and Proposed Order:

WHEREAS, on January 15, 2014, this Court entered its Status (Pretrial Scheduling) Order1 (the "Scheduling Order") which set forth, among other things, discovery and motion deadlines in the above referenced matter;

WHEREAS, the Parties previously postponed overseas depositions in order to conduct informal settlement discussions which were not successful;

WHEREAS, the Parties wish to extend those deadlines set forth in the Scheduling Order as follows, in order to allow additional time for the parties to conduct depositions in foreign countries which require extensive time to schedule and coordinate;

THEREFORE, IT IS HEREBY STIPULATED between counsel for Defendants and counsel for Plaintiff that the discovery and motion deadlines set forth in the Scheduling Order be rescheduled as set forth above.

SO STIPULATED.

[PROPOSED] ORDER

Appearing that good cause exists pursuant to the foregoing stipulation of the Parties, IT IS HEREBY ORDERED that the deadlines for discovery and motions set forth in the Status (Pretrial Scheduling) Order, are rescheduled as follows:

SO ORDERED.