STIPULATION AND [PROPOSED] ORDER TO EXTEND FACT AND EXPERT DISCOVERY DEADLINES TO COMPLETE MEDIATION

RICHARD SEEBORG, District Judge.

Plaintiff NORTH VENTURE PARTNERS, LLC ("Plaintiff"), and Defendant VOCUS, INC ("Defendant") (collectively, "the Parties"), hereby submit this Stipulation and [Proposed] Order to extend fact and expert discovery deadlines in order to complete their mediation.

The Parties herein agree and stipulate as follows:

1. This Court encourages civil litigants to use alternative dispute resolution programs to resolve their disputes in a just, timely, and cost-effective matter (see Civil Local Rule 16-8);

2. The parties have agreed to engage in private mediation scheduled for September 24, 2014;

3. The parties will immediately notify this Court if the mediation is successful;

4. Pursuant to the Case Management Scheduling Order filed April 24, 2014 [ECF Doc #27] ("April 24, 2014 Order"), the Court established the following discovery deadlines, with a trial date set for May 11, 2015:

5. In light of the Parties upcoming mediation, the Parties agree that an extension of certain discovery deadlines in the April 24, 2014 Order will significantly aid in the settlement efforts and allocate the Parties' time and resources to the mediation;

THEREFORE, IT IS STIPULATED, by and between the undersigned parties through their respective counsel of record, that the Court set the following schedule:

1. The completion of non-expert discovery shall be continued to January 23, 2015;

2. The Parties shall designate expert witnesses no later than February 9, 2015;

3. The Parties shall designate supplemental and rebuttal expert witnesses no later than February 23, 2015;

4. Completion of expert witness discovery: March 20, 2015.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

PURSUANT TO STIPULATION, IT IS SO ORDERED