JOINT STIPULATION TO EXTEND SCHEDULING ORDER DEADLINES; AND ORDER THEREON

BARBARA A. McAULIFFE, Magistrate Judge.

Pursuant Rules 16 and 29 of the Federal Rules of Civil Procedure, defendants KAPLAN, INC. and KAPLAN HIGHER EDUCATION, LLC (collectively, "Defendants") and Plaintiff Marcella Jackson ("Plaintiff"), through their respective counsel, hereby jointly submit this stipulation for an order to extend the cutoff deadline for non-expert discovery one month, from October 29, 2014, to December 1, 2014.

WHEREAS, on May 19, 2014, the Court issued a Scheduling Conference Order requiring that non-expert discovery be completed no later than October 29, 2014;

WHEREAS, due to the varied geographic locations of the witnesses, the schedules of the parties and third-party witnesses, and the upcoming trial and hearing dates for Defendants' counsel, the parties are unable to complete non-expert discovery prior to the October 29 deadline;

WHEREAS, the parties believe they require a limited extension of time to complete all non-expert witness depositions and to propound written discovery, without affecting any other deadline established by the Court;

WHEREAS, having reviewed the respective schedules of counsel and the remaining witnesses, the parties believe that non-expert discovery can be completed by or before December 1, 2014.

WHEREAS, the parties have not made any previous requests to extend any discovery deadlines in this action;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the parties through their undersigned counsel of record that:

1. The deadline to complete non-expert discovery should be moved from October 29, 2014, to December 1, 2010.

2. No other deadlines in this action will be altered by this stipulation.

ORDER

GOOD CAUSE APPEARING THEREFOR, the Court hereby approves this Joint Stipulation to Extend Scheduling Order Deadlines.

IT IS SO ORDERED.