STIPULATION AND ORDER EXTENDING THE TIME FOR DEFENDANT TO PRODUCE CERTAIN DOCUMENTS

LUCY H. KOH, District Judge.

Pursuant to Local Rule 6-2, Plaintiff and Defendant, through their respective counsel of record, hereby stipulate and agree as follows:

WHEREAS, Plaintiff served his Request for Production of Documents to Defendant on October 25, 2012.

WHEREAS, Plaintiff agreed to extend the deadline for Defendant to respond to this Request on three occasions, first to December 29, then to January 18, and finally to January 25.

WHEREAS, on January 25, 2013, Defendant served its written response to the Request of Production of Documents.

WHEREAS, on January 30, 2013, the parties appeared before the Court for a further case management conference. During that conference, the Court initiated an inquiry into the timing of Defendant's responses to Plaintiff's discovery and then ordered Defendant to produce all documents by February 8, 2013.

WHEREAS, Defendant has been working diligently with its counsel to collect all responsive, non-objectionable documents and will meet the Court's February 8, 2013 deadline to produce all responsive, non-objectionable documents that it can readily access in its files and on its computer network. Unfortunately, despite its due diligence, Defendant is unable to meet the February 8 deadline to produce responsive documents that have been electronically archived. The process for accessing, searching, and reviewing the electronically archived information going back a number of years is extremely time consuming and, despite due diligence, cannot be completed by February 8. Defendant expects that the process can be completed and any responsive documents produced to Plaintiff by March 8, 2013.

WHEREAS, given that the deadline for Plaintiff to file his motion for class certification is May 23, 2013 and the fact discovery cutoff is November 1, 2013, the requested extension for Defendant's document production to March 8, 2013 will not affect the schedule for this case.

THEREFORE, the parties stipulate and agree, and respectfully request the Court to extend the deadline for Defendant to produce any additional documents to March 8, 2013.

IT IS SO STIPULATED.

ORDER

The Court here by ORDERS that Defendant's deadline to produce additional documents shall be extended to February 22, 2013. No further extensions shall be granted.