JOINT STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES

MORRISON C. ENGLAND, Jr., District Judge.

Pursuant to Local Rule 143 and the Court's June 22, 2016 Initial Pretrial Scheduling Order (Dkt. #2), Plaintiff Tammy Lynn Logan ("Plaintiff") and Defendants Patriot National, Inc., Patriot Risk Services, Inc., Patriot Claim Services, Inc., and Patriot Risk Consultants, Inc., erroneously sued as "Patriot Risk Management, Inc." (collectively, "Defendants"), by and through their counsel of record hereby stipulate and request that the Court enter and Order as follows:

WHEREAS, Plaintiff commenced this action on April 22, 2016 in the Superior Court of the State of California for the County of Sacramento [Dkt. #1, Exhibit A ("Complaint")];

WHEREAS, Defendants removed this action to this Court on June 22, 2016 [Dkt. #1];

WHEREAS, on June 22, 2016 the Court issued an Initial Pretrial Scheduling Order, which scheduled deadlines for discovery, disclosure of expert witness and dispositive motions [Dkt. #2];

WHEREAS, the Court's June 22, 2016 Initial Pretrial Scheduling Order set, inter alia, the following deadlines:

WHEREAS, Plaintiff has noticed the deposition of a number of Defendants' employees who are located out-of-state and are not available prior to the fact discovery deadline;

WHEREAS, the parties require additional time to complete depositions and engage in other discovery after the depositions, if necessary;

WHEREAS, no trial date has been set for this case;

WHEREAS, the proposed extension to the discovery and expert disclosure deadlines will not impact the trial date of this case or any other date involving the Court;

WHEREAS, the parties seek to extend by 60 days the fact discovery, initial expert disclosures and rebuttal expert disclosures deadlines as set by the Court's June 22, 2016 Initial Pretrial Scheduling Order and the parties do not seek to alter any of the other dates in the Court's June 22, 2016 Initial Pretrial Scheduling Order [Dkt. #2];

WHEREAS, in light of the above, good cause exists to extend the current discovery and expert disclosure schedule;

NOW THEREFORE, in consideration of the foregoing, the parties, by and through their undersigned counsel, hereby stipulate, agree and request that the Court enter an Order amending the discovery and expert disclosure deadlines in the Court's June 22, 2016 Initial Pretrial Scheduling Order as follows:

IT IS SO STIPULATED.

IT IS SO ORDERED.