THIRD JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY AND TRIAL DEADLINES

SHEILA K. OBERTO, Magistrate Judge.

Plaintiff United States Equal Employment Opportunity Commission ("EEOC" or "Plaintiff") and Defendant Farmers Insurance Exchange ("Farmers" or "Defendant"), through their respective counsel of record, hereby respectfully request a continuance of the Scheduling Order and accompanying deadlines.

On September 30, 2013, the EEOC filed the instant action pursuant to Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991. Defendant filed a motion to dismiss the action on January 28, 2014, EEOC filed an opposition on February 24, 2014, and Defendant filed a reply on March 3, 2014. On March 4, 2014, the Court took the matter under submission. The Court issued a ruling on the matter on May 30, 2014, denying Defendant's motion to dismiss.

Defendant filed an Answer to the Complaint on June 13, 2014, and an initial scheduling order was issued by the Court in this matter on July 11, 2014.

In the intervening time since, the parties submitted two stipulations to extend time with the most recent occurring on June 2, 2015. In the joint stipulation, the parties anticipated that an in person meeting or mediation would occur in June 2015. As a result of scheduling conflicts and other matters, the in person meeting or mediation did not occur until July 31, 2015. Accordingly, the parties now stipulate pursuant to Rules 16 and 26 of the Federal Rules of Civil Procedure as follows:

1. Good Cause To Extend Discovery Deadlines

The parties come before the Court to seek a third extension of the discovery and trial deadlines. The parties anticipate that this will be the final request for an extension of these deadlines. The parties seek the current extension, which extends most of the current deadlines by approximately three (3) months, to permit the parties to continue to pursue settlement discussions. While no settlement has been reached, the parties have made progress on this matter, conducting an in person meeting on July 31, 2015, following the initial settlement conference with this court, and are planning now to progress further settlement discussions at a private mediation to take place before the Honorable Margaret A. Nagle (Ret.) in November or December 2015. The requested extension will permit both sides to focus on these settlement discussions without diverting resources and attention to litigation matters.

Due to the above-noted reasons as well as other cases and commitments, it has proven difficult to complete the necessary depositions and written discovery prior to the discovery deadline contained in the current scheduling order. As such, the parties request that the Court, for good cause, grant the parties' third request for an extension of time.

2. Proposed New Schedule

The parties stipulate that the Joint Scheduling Order be amended to reflect the following new deadlines:

IT IS SO STIPULATED.

ORDER

For good cause shown, the parties' joint stipulation to extend discovery deadlines (Doc. 35) is hereby approved and the new deadlines for discovery set forth in the Scheduling Order shall be amended as follows:

IT IS SO ORDERED.