JOINT STIPULATION AND REQUEST TO EXTEND CERTAIN SCHEDULING DATES; ORDER GRANTING IN PART

(Doc. 23)

JENNIFER L. THURSTON, Magistrate Judge.

TO THIS HONORABLE COURT:

Plaintiff Leonel Rojas Rivera, by and through his attorneys of record, and Defendant AgReserves, Inc. dba South Valley Farms ("AgReserves") by and through their attorneys of record, hereby stipulate to request that the Court extend certain Scheduling Order dates [Docket No. 17] — specifically the non-expert discovery cut-off, the expert discovery cut off, the deadline for Plaintiff to file class certification motion, and dispositive motion hearing cut-off dates, as follows:

WHEREAS, the Parties have worked diligently to conduct discovery in this matter, including exchanging and responding to the initial set of written discovery by both sides, and taking the deposition of Plaintiff Leonel Rojas Rivera;

WHEREAS, despite the Parties' efforts, a substantial amount of discovery to be conducted, including but not limited to, additional written discovery regarding class certification issues, and the potential need for additional depositions;

WHEREAS, the Parties are working diligently to complete this long discovery process;

WHEREAS, the Parties have agreed to participate in a private mediation in this matter on May 31, 2016;

WHEREAS, if the matter does not resolve upon private mediation, the parties would like more time to prepare additional discovery by mutually agreeing to extend operative scheduling dates from the Scheduling Order;

WHEREAS, the current operative dates [Docket No. 17] are as follows:

WHEREAS, the Parties propose a continuance of the previously calendared dates to allow for proper discovery and full exploration of mediation options, as follows:

IT IS SO STIPULATED.

ORDER

Based upon the stipulation and after conducting an informal telephonic conference with counsel, the Court ORDERS:

1. The stipulation is GRANTED in PART as follows:

a. The deposition of Plaintiff and the Fed. R. Civ. P. 30(b) deponent SHALL be completed no later than July 15, 2016;

b. Expert disclosures SHALL be made no later than July 29, 2016 and rebuttal experts disclosed no later than August 26, 2016;

c. Expert discovery SHALL be completed no later than September 16, 2016;

d. Non-dispositive motions SHALL be filed no later than September 30, 2016 and heard no later than October 28, 2016;

e. The motion for class certification SHALL be filed no later than November 25, 2016;

f. Opposition to the motion for class certification SHALL be filed no later than January 13, 2017;

g. The reply to the opposition to the motion for class certification SHALL be filed no later than February 10, 2017;

h. The hearing on the motion for class certification is CONTINUED to February 27, 2017 at 9:30 a.m.

No other modifications to the case schedule are authorized.

IT IS SO ORDERED.