JOINT STIPULATION FOR THE CONTINUANCE OF MEDIATION, NON-EXPERT DISCOVERY, DISPOSITIVE MOTIONS, EXPERT DISCLOSURE DEADLINES

NATHANAEL M. COUSINS, Magistrate Judge.

The plaintiff, Allen Shahan, and the defendant, Golden State Bridge, Inc., through their respective counsel, submit the following Joint Stipulation to continue the deadline:

1. On October 30, 2014, this Court issued a Case Management Scheduling Order setting September 3, 2014 as the deadline to file all dispositive motions [excepting "summary judgment motions on the plaintiff's alleged status as a seaman" which was then set for April 11, 2014]. See Court Docket, Document No. 19. On May 7, 2014, this Court issued a Case Management Scheduling Order which set August 26, 2014 as the deadline to complete mediation, August 29, 2014 as the deadline to complete non-expert discovery, September 26, 2014 as the date of plaintiff's expert disclosure, and October 3, 2014 as the date of defendant's expert disclosure. See Court Docket, Document No. 28.

2. Since May 7, 2014, the parties have worked diligently towards completing discovery.

3. However, the parties have had difficulty in taking and/or completing the depositions of percipient witnesses Jim Banbury, Michael Ford, David Webb and Donovan Kelly. The parties have had difficulty scheduling the depositions of the witnesses because the witnesses have either been working on projects where their work and involvement is necessary, they have been working out of the San Francisco Bay Area or the parties have had difficulty, despite diligent efforts, to contact witnesses.

4. The parties are also in the process of coordinating the independent medical examinations of plaintiff, to include separate medical examinations to be conducted by a psychologist, psychiatrist, neuro-psychiatrist and possibly an orthopaedic surgeon. In light of each expert's specialty, each examination will likely have to be conducted on separate days.

5. The continuance of the deadlines to complete mediation from August 26, 2014 to September 26, 2014 and the deadline to complete non-expert discovery from August 29, 2014 to September 30, 2014 are necessary to allow the parties to conduct necessary discovery and will allow the parties to have a more productive mediation. Continuing the deadline to file dispositive motions [excepting "summary judgment motions on the plaintiff's alleged status as a seaman"] from September 3, 2014 to October 3, 2014, and continuing the deadline for plaintiff's expert disclosure from September 26, 2014 to October 3, 2014, and the deadline for defendant's expert disclosure from October 3, 2014 to October 10, 2014, will allow each party and their respective experts to consider all relevant evidence exchanged as part of the new discovery deadline.

CERTIFICATE OF SIGNATURE

I attest that the content of this document is acceptable to attorney, John R. Hillsman, and that he authorized me to sign the document on his behalf.

[PROPOSED] Amendment to Case Management Order

The Joint Stipulation and Proposed Order is hereby adopted by the Court and the parties are ordered to comply with this Order. The Court hereby continues the deadline:

IT IS SO ORDERED.