STIPULATION AND [PROPOSED] ORDER TO PARTIALLY REVISE THE COURT'S SCHEDULING ORDER

JON S. TIGAR, District Judge.

Plaintiff Jason-Issa Karkar and State Farm General Insurance Company ("State Farm"), by and through their respective counsel, hereby stipulate to revise the Court's July 17, 2014 Scheduling Order (Dkt 17) as follows:

I.

RECITALS

1. The parties have been working diligently toward moving this case forward in an efficient and expeditious manner. The current deadline to complete fact discovery is February 2, 2015. Despite the parties' diligent efforts and cooperation to complete the depositions of fact witnesses, there are certain fact witnesses whose depositions cannot be scheduled by that date due to the lack of mutually available dates between and among counsel and the remaining witnesses, and the intervening holiday season. For that reason, the parties have agreed to stipulate to a proposed order extending the deadline for fact discovery, the deadlines for expert disclosure, rebuttal disclosure, and expert discovery, to enable the parties to complete fact and expert discovery without incurring undue burden and expense.

2. The parties do not seek to continue the deadline to file dispositive motions, the pretrial conference date, or the trial date. However, the parties have agreed that if State Farm files a motion for summary judgment or summary adjudication on May 1, 2015, which is the last day to file dispositive motions, that the briefing schedule be set as follows: opposition papers due June 18, 2015 and reply papers due June 25, 2015. The parties further request a hearing date of July 9, 2015 for any dispositive motion filed by State Farm on May 1, 2015. The parties do not believe this extended briefing schedule negatively impacts the pretrial conference date or the trial date. This stipulation does not preclude State Farm from filing its dispositive motion earlier than May 1, 2015, with deadlines per Local Rule 7-3.

II.

STIPULATION

The parties hereby stipulate to the following revisions to the court's Pretrial Schedule:

If any dispositive motion is filed on the last day (May 1, 2015), the parties hereby agree to the following briefing schedule: Opposition — June 18, 2015; Reply — June 25, 2015; Hearing — July 9, 2015.

[PROPOSED] ORDER

Pursuant to the parties' stipulation, the Pretrial Schedule is revised as follows:

If either party files a dispositive motion on the last day listed above (May 1, 2015), the following briefing schedule shall be used: Opposition — June 18, 2015 Reply — June 25, 2015; Hearing — July 9, 2015 at 2:00 p.m.. State Farm is not precluded from filing its dispositive motion earlier than May 1, 2015, with deadlines per Local Rule 7-3.

The remaining dates and deadlines set forth in the Scheduling Order, dated July 17, 2014 (Dkt 17) remain unchanged.

IT IS SO ORDERED.