STIPULATION OF THE PARTIES REGARDING INDEPENDENT MENTAL EXAMINATION; ORDER

EDMUND F. BRENNAN, Magistrate Judge.

It is hereby stipulated and agreed by and between Plaintiff, Armando Ramos by and through his attorney of record and Defendant, Williams Unified School District and Judith Rossi, through their attorneys of record that Armando Ramos will submit to an independent mental examination to be performed as follows:

(1) Dr. Ronald H. Roberts, Ph.D., ABPD on March 30, 2018, starting at 10:00 a.m. at M.O.A. Deposition Reporters, 855 Harter Parkway, Ste. 210, Yuba City, CA 95993;

The examination to be performed by Dr. Roberts will consist of psychological testing. It is anticipated the duration of the psychological testing will take approximately four (4) hours, excluding appropriate breaks. Additional time will be allowed, as needed, only to facilitate any needed rest breaks; and

(2) Dr. Charles Saldanha, MD, on April 13, 2018 at 10:00 a.m., at M.O.A. Deposition Reporters, 855 Harter Parkway, Ste. 210, Yuba City, CA 95993, will conduct a detailed psychiatric interview lasting approximately five (5) hours. Additional time will be allowed, as needed, only to facilitate any needed rest break.

Dr. Roberts' and Dr. Saldanha's resumes are attached hereto.

No attorneys or other third parties shall be present during the testing and interview with Armando Ramos. The psychiatric interview will be recorded by audio and copies of the interview made available to both parties. Plaintiff Armando Ramos may also record the examination. It is agreed the interview is not for purposes of collecting factual information to defend liability in this case and that it is exclusively to evaluate Plaintiff Armando Ramos' emotional and psychiatric state, third party rights of privacy will be maintained.

The total time spent testing and interviewing Armando Ramos will likely be no more than 10-12 hours.

Plaintiff will obtain, via authorizations signed by Armando Ramos, the following categories of documents:

1. VA records; and

2. The documents responsive to the Subpoena served on Greene and Roberts.

Upon production of the above-referenced documents Plaintiff will produce all of them except those that Plaintiff contends are privileged. As to privileged documents, Plaintiff agrees to prepare and serve a privilege log by March 23, 2018. The parties will then meet and confer about the documents over which there is disagreement. Absent resolution, the parties agree to submit the issue to the court.

IT IS SO STIPULATED.

IT IS SO ORDERED.