STIPULATION AND PROPOSED ORDER RE: RULE 35 EXAMINATION

DISCOVERY MATTER

ALLISON CLAIRE, Magistrate Judge.

IT IS HEREBY STIPULATED, by and between the parties through their undersigned counsel, as follows:

1. Plaintiff Nora Washington will undergo a mental examination conducted by Dr. Mark Strassberg, M.D., at 2710 Gateway Oaks Drive, Suite 300-South, Sacramento, California, Zip Code 95833. The examination will occur on April 18, 2020, at 10:00 a.m. The examination, including the time required for face-to-face interviewing, will take approximately 4 to 5 hours to complete.

2. Dr. Strassberg will examine Plaintiff psychiatrically, to include a history of the mental and emotional difficulties she attributes to the incident on August 3, 2017, and her treatment, response to treatment, and current complaints. A historical review of family, interpersonal relationships, work, and educational history will be pursued as well as Plaintiff's past medical and psychiatric history.

3. Dr. Strassberg will also examine Plaintiff neurologically, to include strength, sensation, balance, reflex, vision, and coordination.

4. At the time of the examination, Plaintiff shall answer all inquiries made by Dr. Strassberg so that he can evaluate the nature, extent, and cause of Plaintiff's condition as well as her prognosis.

5. No observers shall attend the examination. Plaintiff shall not record any portion of the examination. Dr. Strassberg shall audio-record the examination, and Defendant shall provide Plaintiff's counsel with a copy of the recording.

6. Dr. Strassberg shall receive a copy of this executed Stipulation.

7. Defendant shall provide Plaintiff's counsel with a report of the examination consistent with Federal Rules of Civil Procedure 35(b) within 30 days of the examination.

8. The cost of the examination shall be borne by the Defendant.

IT IS SO ORDERED.