STIPULATION AND ORDER TO EXTEND DEADLINES IN SCHEDULING ORDER

TROY L. NUNLEY, District Judge.

Plaintiffs LELAND LENNAR and NARVELL HENRY ("Plaintiffs") and Defendants DIAMOND PET FOOD PROCESSORS OF CALIFORNIA, LLC; DIAMOND PET FOOD PROCESSORS OF RIPON, LLC, and SCHELL & KAMPETER, INC. (dba) DIAMAOND PET FOODS (hereinafter, collectively referred to as "Defendants") hereby jointly stipulate and seek leave pursuant to Rule 16(b) of the Federal Rules of Civil Procedure to extend the deadlines set forth in the Status (Pretrial Scheduling) Scheduling Order (hereinafter the "Scheduling Order") for good cause as set forth herein.

Plaintiffs' lawsuit asserts claims against Defendants for race harassment, race discrimination, wrongful termination, and retaliation under state and federal law. Plaintiffs filed the initial Complaint on September 9, 2013, and Defendants filed their Answer on October 10, 2013. Plaintiff seeks special damages in the form of past and future earnings, employment benefits, loss of earning capacity, general damages, punitive damages, and attorneys' fees. Defendants deny liability.

On January 29, 2014, this Court issued a Pre-Trial Scheduling Order without hearing. According to the Order, the deadline for non-expert discovery is September 19, 2014, the expert disclosure deadline is November 20, 2014, the last date for dispositive motions is March 12, 2015, and the jury trial is scheduled for August 17, 2015.

On July 8, 2014, this Court granted the parties' Stipulation Extending Deadlines in the Discovery Order and revised the deadline for non-expert discovery to November 20, 2014 and the expert disclosure deadline to December 17, 2014. The other deadlines remained the same.

Most of the non-expert discovery will be completed in the next few weeks. However, the parties are currently meeting and conferring on issues concerning written discovery responses, and need additional time to complete this process. Currently, any motion to compel concerning deficient discovery responses must be filed by October 30, 2014, in order to be heard by November 20, 2014, assuming the Court has availability to hear a motion on that date.

Thus, the parties seek a brief extension of the deadline to complete non-expert discovery. The parties seek to extend the deadline to complete non-expert discovery from November 20, 2014 to December 22, 2014. The other deadlines shall remain the same.

In light of the foregoing, and for good cause shown, the parties respectfully request that the Court modify the existing Scheduling Order as agreed by the parties and as set forth herein. This extension does not affect the dates related to dispositive motions, the pretrial conference date, or the trial date, although those dates are included below for sake of context.

ORDER

Pursuant to the joint stipulation of the parties, and good cause appearing, the deadline for completion of discovery is hereby continued from November 20, 2014 to December 22, 2014. All other dates remain the same.

IT IS SO ORDERED.