STIPULATION AND ORDER MODIFYING PRE-TRIAL SCHEDULING ORDER

JOHN A. MENDEZ, District Judge.

Plaintiff JAMIE IRELAND ("Plaintiff") and Defendants LINDER PSYCHIATRIC GROUP, INC., DAVID LINDER, M.D., and RENAE LINDER (collectively, "Defendants"), by and through their counsel of record, hereby submit the following stipulation and [proposed] Order to modify the Pre-Trial Scheduling Order (Dckt. # 13) to continue the trial, and all related deadlines and currently scheduled dates, as follows:

WHEREAS the Parties have agreed to and scheduled mediation, to take place on December 11, 2015;

WHEREAS the Parties have engaged in written discovery and have essential depositions that have not yet been scheduled;

WHEREAS the expert witness disclosures deadline is December 4, 2015;

WHEREAS the Parties agree that the time and expense associated with completing depositions and preparing expert witness disclosures will impede the ability to mediate and resolve this case;

WHEREAS the Parties intend to conduct further discovery if mediation is not successful;

WHEREAS the Parties and their counsel agree that an Order modifying the Pre-Trial Scheduling Order will not prejudice the Parties and can be issued forthwith;

WHEREAS the Parties and their counsel agree that this Stipulation is made in good faith and not for any improper purpose;

WHEREAS there have been no previous modifications of the Pre-Trial Scheduling Order in this matter;

WHEREAS good cause exists to modify the scheduling order, to allow the Parties to meaningfully engage in further settlement discussions, private mediation, and to conduct further discovery if the Parties do not reach a settlement.

NOW THEREFORE, IT IS HEREBY STIPULATED by and between the Parties, that:

1. All dates in the Scheduling Order will be continued, subject to Court approval, to allow the Parties to meaningfully engage in further settlement discussions, private mediation, and to conduct further discovery if the Parties do not reach a settlement. The Parties propose the following new scheduling deadlines and dates, which are mutually agreeable to the Parties, or dates thereafter:

2. The Parties agree to accept these proposed dates, or such later dates as the Court may reasonably set in its discretion, subject to any subsequent adjustment necessary for good cause shown.

3. Based on the foregoing, the Parties respectfully request this Court enter an Order consistent with this Stipulation.

IT IS SO STIPULATED.

ORDER (AS AMENDED BY THE COURT)

Based upon the Stipulation of the parties and good cause appearing therefore, IT IS SO ORDERED.