[PROPOSED] STIPULATION TO MODIFY SCHEDULING ORDER TO EXTEND DISCOVERY COMPLETION DEADLINES

ALLISON CLAIRE, Magistrate Judge.

All parties to this lawsuit, by and through their respective attorneys, stipulate and agree to request that this court modify the existing scheduling order issued by this court on January 29, 2015 to extend the time to complete discovery until April 27, 2015. This joint request is based on the following:

1. On January 26, 2015, the parties herein filed a stipulation and proposed order to extend pretrial deadlines and requested that the court refer this case to a settlement conference with Magistrate Judge Delaney. The reason for the request was to allow the parties to conduct a settlement conference with Judge Delaney for a date in March 2015, before the expert disclosure deadline, and to allow the parties an additional two weeks to complete discovery if necessary, after the parties attended the settlement conference.

2. On January 29, 2015, the court issued an order setting a discovery deadline of March 27, 2015, expert disclosure May 18, 2015, completion of expert discovery by June 8, 2015, and a last day to file dispositive motions on June 29, 2015. The Court also issued an order that the parties attend a settlement conference with Magistrate Judge Delaney on March 13, 2015 at 9:30 a.m.

3. The parties at this time have been attempting to schedule various depositions, including the deposition of the plaintiff, the deposition of defendant Alvarez, the depositions of defendants employed by the West Sacramento Police Department, and some percipient witness depositions. However, the parties wish to avoid incurring costs of deposition and other discovery before the settlement conference. However, the current scheduling order requires discovery completion by March 27, 2015, therefore, if the matter is not resolved at the settlement conference, the parties will only have two weeks to complete discovery. The parties believe that by extending the discovery cut off another thirty (30) days, there will be adequate time to conduct the discovery if the case is not settled, in manner which is mutually convenient to the schedule of the attorneys herein, and without effecting any of the other pretrial dates scheduled in the case.

Therefore, all parties request that the scheduling order of January 29, 2015 be amended to set the deadline to complete discovery be extended by thirty (30) days to April 27, 2015.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

PURSUANT TO STIPULATION, IT IS SO ORDERED.