STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES

JON S. TIGAR, District Judge.

Whereas, on April 10, 2013, the Court entered an Order (Document 20) setting fact discovery cutoff on August 16, 2013, expert disclosures on October 4, expert rebuttal disclosures on November 1, and expert discovery cutoff on November 22;

Whereas, the deadline to file dispositive motions is not until January 24, 2014, and trial is scheduled on April 28, 2014, allowing sufficient time that a 60-day extension of the discovery deadlines would not require a change in the trial date;

Whereas, on June 25, 2013, Defendant Teamsters Local 948 filed a motion to disqualify Plaintiffs' counsel, on the grounds that Plaintiffs' counsel formerly represented Defendant and Defendant contends that Plaintiffs' counsel has a conflict, and that motion is scheduled to be heard on August 29, 2013;

Whereas, Plaintiffs seek to take the depositions of officers and employees of Defendant, and Defendant objects to submitting to examination by Plaintiffs' counsel while the motion to disqualify him is pending;

Now, therefore, the parties hereby stipulate as follows:

The depositions of Defendant's Secretary-Treasurer Adam Ochoa and Defendant's business agent Luis Diaz, noticed for August 2, are cancelled;

To allow time for the parties to complete discovery after the Court decides the motion to disqualify, which is scheduled to be heard on August 29, the parties jointly request an extension of the discovery deadlines by 60 days, which will reschedule the deadlines as follows:

[PROPOSED] ORDER

The Court having considered the above Stipulation of the parties, and good cause appearing, the discovery deadlines in the above-captioned matter are hereby extended as follows:

IT IS SO ORDERED.