JOINT STIPULATION TO EXTEND DATES AND DEADLINES; [PROPOSED] ORDER

JENNIFER L. THURSTON, Magistrate Judge.

TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that Plaintiff KIM ADAMS, an individual, and Defendants COUNTY OF KERN; KERN COUNTY PROBATION DEPARTMENT; DAVID M. KUGE, an individual; REYES SOBERON, JR., an individual; and DOES 1 through 50 (hereafter collectively the "parties"), by and through their counsel of record, hereby stipulate and agree as follows:

WHEREAS the parties entered a previous Joint Stipulation to Extend Dates and Deadlines that was approved by the Court on September 13, 2018.

WHEREAS Plaintiff's son subsequently sustained serious gunshot wounds on February 11, 2019;

WHEREAS Plaintiff's son is currently hospitalized in critical condition and Plaintiff must attend to his medical care under these dire circumstances;

WHEREAS Plaintiff's obligations to her son have limited her availability and rendered her unable to sit for deposition and submit to other discovery requests, such as a mental health examination pursuant to Rule 35, until late May 2019;

WHEREAS the parties have diligently pursued discovery in this matter, having produced documents and scheduled depositions of all defense witnesses;

WHEREAS on March 13, 2019, the remittitur in Plaintiff's appeal of her state case in the California Court of Appeal, Fifth Appellate District (Case No. F075266) was issued affirming the trial court's order denying Adams's petition for relief from the claim presentation requirements. Defendants, not knowing what state law claims Plaintiff would amend to include in this action had Plaintiff prevailed, were reluctant to take Plaintiff's deposition prior to the resolution of the appeal;

WHEREAS the parties have agreed to extend the dates and deadlines in this matter as outlined below:

WHEREAS, the parties agree that there is good cause for these stipulated changes in dates and deadlines.

THEREFORE, the parties hereby stipulate to the changes in all dates and deadlines as outlined above.

IT IS SO STIPULATED.

[PROPOSED] ORDER

IT IS SO ORDERED.