STIPULATED REQUEST TO DISCOVERY AND EXPERT DEADLINES; [PROPOSED] ORDER

VINCE CHHABRIA, District Judge.

Defendants JOSEPH RICHARDS and BRITTANY HAWKS (hereinafter "SRJC Defendants), and COUNTY OF SONOMA, STEVE FREITAS, and RANDALL WALKER (hereinafter "COUNTY Defendants), and plaintiff GEORGE DANIEL (hereinafter "DANIEL"), hereby stipulate as follows:

1. The initial Complaint against the Defendants was filed in this matter on May 29, 2014. Plaintiff's Second Amended Complaint was filed on April 25, 2014.

2. Pursuant to the Scheduling Order dated July 29, 2014 issued by the Court, the following deadlines were set:

(a) Fact Discovery cutoff: October 21, 2014;

(b) Disclosure of Experts: October 29, 2014

(c) Expert Discovery cutoff: November 20, 2014;

(d) Trial: June 22, 2015.

4. On September 5, 2014, SRJC Defendants propounded Requests for Production of Documents, Interrogatories, and Requests for Admission to DANIEL.

5. On September 11, 2014, COUNTY Defendants propounded Requests for Production of Documents, Interrogatories, and Requests for Admission to DANIEL.

6. On September 29, 2014, DANIEL filed an Ex Parte Motion for Extension of Time to Complete Discovery.

7. On October 2, 2014, the Court issued an Order Denying DANIEL's Motion for an Extension of Time. The Court noted in its Order it "is inclined to extend the discovery deadline for 21 days if the plaintiff first seeks the consent of all parties and submits a stipulated request for a 21-day extension of that."

8. The parties submit the present Stipulation to request the discovery extension noted in the Court's October 2, 2014 Order.

9. The parties therefore stipulate to the following extension of presently set discovery deadlines:

(a) Fact Discovery cutoff shall be extended from October 21, 2014 to November 11, 2014;

(b) Disclosure of Experts shall be extended from October 29, 2014 to November 19, 2014;

(c) Expert Discovery cutoff shall be extended from November 20, 2014 to December 11,2014.

10. These stipulated extensions will not alter any other events or deadlines already fixed by Court order.

[PROPOSED] ORDER

Upon the foregoing Stipulation, and for good cause shown, IT IS ORDERED that Fact Discovery shall be completed by November 11, 2014, Disclosure of Experts shall be made by November 19, 2014, and Expert Discovery shall be completed by December 11, 2014.