JOINT STIPULATION RE REQUEST TO CONTINUE TRIAL AND DISCOVERY DATES

(Doc. 20)

JENNIFER L. THURSTON, Magistrate Judge.

Plaintiff Josephine Hernandez and Defendant The GEO Group, Inc. d/b/a GEO California, Inc. and GEO Corrections and Detention, LLC (collectively, the "Parties") by and through their respective counsel of record hereby stipulate and respectfully request the Court continue the trial and discovery dates in the above-reference matter, as follows:

WHEREAS, on February 17, 2016 the Parties filed their Joint Scheduling Report in the above-captioned matter;

WHEREAS, on February 25, 2016, the Court issued an Order setting Trial for March 28, 2017 and Pretrial Conference for February 10, 2017, and set the Discovery Deadlines in the above-captioned matter;

WHEREAS, the Parties have experienced unexpected delays in discovery in this matter;

WHEREAS, Plaintiff's counsel was diagnosed with an illness and required treatment for the same;

WHEREAS, Plaintiff's continued deposition was unexpectedly cancelled the day before it was to take place as a result of Plaintiff's move to Sacramento, California. The deposition is currently scheduled for September 23, 2015;

WHEREAS, the deposition of Pratrap Misra was unexpectedly cancelled due to Mr. Misra's medical emergency. The parties are discussing a potential deposition date in mid-September for Mr. Misra's deposition;

WHEREAS, the Parties have agreed that Plaintiff will participate in an independent medical examination ("IME"); however, Plaintiff's deposition must be completed prior to the IME to allow Defendants to obtain the relevant testimony, documents and subsequently obtained records related to Plaintiff's claims for emotional distress damages necessary to allow for an effective and complete IME;

WHEREAS, the completion of Plaintiff's deposition and IME are necessary for the drafting and filing of Defendants' dispositive motion;

WHEREAS, Plaintiff wishes to complete the deposition of several key witnesses, including Pratrap Misra, Warden Wanda Wilson, and the PMK of Defendant regarding the decision to terminate Plaintiff, but has not been able to as a result of the unexpected delays stated above;

WHEREAS, the Discovery Deadline is currently set for October 31, 2016 for non-expert discovery and December 5, 2016 for expert discovery, and the Parties anticipate they will not be able to complete all necessary discovery prior to those dates;

WHEREAS, the Parties have reviewed their trial calendars and both are available to begin trial on June 1, 2017, or a date shortly thereafter convenient with the Court;

THEREFORE, the Parties respectfully request that the Court continue the current dates as follows:

ORDER

Based upon the stipulation of counsel and the unforeseen difficulties that have arisen in completing discovery, the Court ORDERS the case schedule amended as follows:

1. All non-expert discovery SHALL be completed by 1/26/17:

2. All expert discovery SHALL be completed by 3/6/17;

3. The parties SHALL disclose their experts no later than 2/3/17 and any rebuttal experts by 3/17/17;

4. Any nondispositive motion SHALL be filed no later than 2/13/17 and heard no later than 3/13/17;

5. Any dispositive motion SHALL be filed no later than 3/13/17 and heard no later than 4/17/17;

6. The pretrial conference is set on 5/15/17 at 9:00 a.m.;

7. The trial is set on 7/24/17 at 8:30 a.m.

Absolutely no further request to modify the case schedule will be entertained absent a showing of extraordinary good cause.

IT IS SO ORDERED.