STIPULATION AND ORDER TO AMEND SCHEDULING ORDER

TROY L. NUNLEY, District Judge.

Mary Cecchini Ray ("Plaintiff") and Mid Valley Agricultural Services, Inc. ("Defendant"), by and through their respective attorneys of record and pursuant to USDC ED CA Local Rules 143 and 144(d) and Federal Rule of Civil Procedure 16(b), hereby stipulate and agree as follows:

WHEREAS, on or about September 24, 2018, this Court, pursuant to Federal Rule of Civil Procedure ("FRCP") 16(b), issued a Pretrial Scheduling Order setting the close of fact discovery two hundred forty (240) days from the date upon which the last answer was filed, and setting other case management deadlines based on the date discovery closed. (Doc. 3);

WHEREAS, on or about December 12, 2018, and pursuant to FRCP 26(f)(2) and Local Rule 240(b), the parties filed a Joint Status Report enumerating the complexities in this case which would affect the scope of discovery and requesting the Court amend the scheduling deadlines set in the Pretrial Scheduling Order for purposes of accommodating expansive discovery. (Doc. 7)

WHEREAS, on or about April 4, 2019, Plaintiff and Defendant submitted a Stipulation and Proposed Order to Amend the Scheduling Order in accordance with the request made in the Joint Statute Report. This Stipulation was granted by the Court on April 5, 2019. (Docs. 9, 10)

WHEREAS, the parties have been working diligently towards completing fact discovery as follows. The parties exchanged multiple sets of written discovery. Defendant conducted an extensive e-discovery review and production. The parties took the depositions of Plaintiff and Defendant's CEO. Plaintiff is taking a second defense deposition on November 20, 2019.

WHEREAS, the parties recently agreed to mediate this case on January 13, 2020 with Debra Mellinkoff, a well-respected mediator in the field of employment law. In anticipation of these negotiations, the parties exchanged meaningful settlement demands.

WHEREAS, good cause exists to extend the deadline for fact discovery and all other pre-trial deadlines for at least two months while the parties attempt to resolve this matter through mediation. Without this relief, the parties will necessarily incur substantial costs and fees for fact discovery while the session is pending. The parties will also incur the extraordinary expense of retraining experts. All of these significant costs and fees stand to be avoided if the case settles at mediation. As the mediation is set two months' out, the parties request at least a two-month extension of all pre-trial deadlines. Granting this relief would be the second amendment to the Pretrial Scheduling Order.

NOW THEREFORE, the parties, through their respective counsel, jointly propose and stipulate to the following:

The deadlines in the Pretrial Scheduling Order as revised by the Court on April 5, 2019 shall be amended as follows, or set on such other dates the Court determines:

IT IS FURTHER STIPULATED AND AGREED between the parties that all other provisions of the Pretrial Scheduling Order as modified by the Court on April 5, 2019 shall remain in effect. This Stipulation may be signed in counterparts and any facsimile or electronic signature shall be valid as an original signature.

IT IS SO STIPULATED.

ORDER

FOR GOOD CAUSE SHOWN, and pursuant to the Stipulation of the parties, the deadlines in the Pretrial Scheduling Order (Doc. 3) as modified by the Court on April 5, 2019 (Doc. 10) are revised as follows; all other provisions of the Pretrial Scheduling Order to remain in effect:

IT IS SO ORDERED.