STIPULATION AND [PROPOSED] ORDER REGARDING THE TAKING OF ADDITIONAL DEPOSITIONS

WILLIAM B. SHUBB, District Judge.

This stipulation is entered into by and between Plaintiff, Glenn-Colusa Irrigation District (Plaintiff); and Defendants, United States Army Corps of Engineers (USACE), R.D. James, Assistant Secretary of the Army for Civil Works1, Lieutenant General Todd T. Semonite, Commanding General and Chief of Engineers, USACE, and Colonel David Ray, District Commander, USACE, Sacramento District (collectively, "Defendants").

WHEREAS, Plaintiff and Defendants (collectively, the "Parties") are engaged in litigation in the above-captioned matter; and

WHEREAS, Rule 30(a)(2) of the Federal Rules of Civil Procedure establishes a presumptive limit of ten (10) depositions each for plaintiffs and defendants; and

WHEREAS, Defendant USACE, through its initial disclosures and responses to other discovery, has identified at least eighteen (18) individuals, including staff, consultants, and experts, who may have relevant information related to Plaintiff's claims; and

WHEREAS, Plaintiff further identified at least two (2) individuals as non-retained experts having relevant information to Plaintiff's claims; and

WHEREAS, the duration of the dispute underlying this litigation and complexity of the issues involved in this matter require that Plaintiff take additional depositions beyond the presumptive limit in Rule 30(a)(2); and

WHEREAS, the Parties have conferred regarding the subject of Plaintiff taking additional depositions in this matter; and

NOW, THEREFORE, the Parties hereby stipulate, and respectfully request that the Court so order, that the following Stipulation shall govern in the instant case:

1. Pursuant to Rule 30(a)(2) of the Federal Rules of Civil Procedure, the Parties agree to allow Plaintiff to take up to ten (10) depositions beyond the presumptive limit of ten (10) depositions, for a total of twenty (20) depositions in this matter.

2. This Stipulation may be executed in counterparts.

IT IS SO STIPULATED.

ORDER

The Court, having considered the stipulation submitted herewith, hereby makes the following order:

Plaintiff Glenn-Colusa Irrigation District may take ten (10) depositions beyond the presumptive limit of ten (10) depositions outlined in the Federal Rules of Civil Procedure, for a total of twenty (20) depositions.

IT IS SO ORDERED.