STIPULATION AND ORDER TO EXTEND EXERT DISCOVERY

JOHN A. MENDEZ, District Judge.

IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ROBERT REESE and Defendants COUNTY OF SACRAMENTO, SCOTT JONES, JOSEPH MILLICAN, ZACHARY ROSE, and DUNCAN BROWN, by and through their undersigned Counsel, pursuant to Local Rules 143 as follows:

1. The parties respectfully request that the District Court modify the Pretrial Scheduling Order to extend expert discovery to allow for additional time to conduct depositions of one of Defendants' expert witnesses, based on good cause appearing as more fully set forth below.

2. Plaintiff agrees to extend the expert discovery deadline and allow Defendants up to and including May 31, 2015, to produce Defense Expert Dr. Jamie Bigelow. The close of discovery deadline is currently April 30, 2015. This extension shall not apply to any other expert or deadline.

3. Good cause exists to extend time due to the Court's recent order dated March 23, 2015, to allow 10 additional depositions to go forward (Document 45) as well as the availability and scheduling conflicts of experts and counsel. The parties have scheduled 16 depositions in the month of April, including Rule 30(b)(6) depositions, and the depositions of non-retained and retained experts. Only one of which is now unable to move forward prior to the close of discovery due to conflicts. This expert is a practicing physician with a demanding schedule and has two other cases in which she has been retained on that are going to trial in the month of April. Thus, accommodating Counsel's schedule, the additional depositions allowed and the experts' conflicts and availability have made it difficult, if not impossible to complete all expert depositions prior to April 30, 2015. The parties submit good cause exists to further modify the scheduling order to allow defense expert, Dr. Bigelow, to be deposed by May 31, 2015.

4. The parties have previously modified discovery and expert disclosure deadlines on three prior occasions by Stipulation and Order on March 5, 2014 (Document 18), June 17, 2014 (Document 20) and January 5, 2015 (Document 31.) The other deadlines including the dates originally set for trial, pretrial conference and dispositive hearing, as well as the associated deadlines, was previously modified by the Scheduling Order on June 17, 2014 (Document 20.)

This Stipulation may be signed in counterparts and any facsimile or electronic signature shall be as valid as an original signature.

IT IS SO STIPULATED.

ORDER

Having reviewed the above stipulation and good cause appearing therefore, IT IS HEREBY ORDERED that the Pretrial Scheduling Order, be modified and expert discovery be extended from April 30, 2015 to May 31, 2015, for the sole purpose of producing Defense Expert Dr. Jamie Bigelow for deposition.

IT IS SO ORDERED.