STIPULATED REQUEST FOR ORDER CHANGING DISCOVERY DEADLINES AND DECLARATION IN SUPPORT THEREOF AND ORDER THEREON

MAXINE M. CHESNEY, District Judge.

STIPULATION

Pursuant to Northern District Local Rules 5 and 6-2, Plaintiff Nelson Carballo ("Plaintiff") and Defendants Comcast Cable Communications Management, LLC, erroneously sued as "Comcast, Inc., Comcast Cable Communications LLC, Comcast Holdings Corporation, Comcast Corporation ("Comcast"), and Communication Workers of America (collectively, the "Parties") hereby stipulate and agree, as follows:

IT IS HEREBY STIPULATED, the Parties, by and through their undersigned counsel, voluntarily agree to extend the discovery deadlines as follows:

DECLARATION

The parties agree that an extension of the above deadlines is necessary to sufficiently prepare for trial. Due to several scheduling conflicts, the parties only recently concluded depositions on April 30, 2015. As such, transcripts from several depositions have not yet been received by the parties. These transcripts are imperative to completing discovery and educating each expert on the facts of this case. Without these deposition transcripts, experts are unlikely to make informed opinions concerning the relevant issues in this case. Similarly, many relevant documents were only recently discovered by Plaintiff and must be reviewed and prepared to sufficiently comply with Comcast's discovery requests. In sum, a two week extension as detailed above would provide the parties a reasonable time frame to sufficiently wind up discovery.

The previous time modifications in the case are as follows:

(1) On December 24, 2013, the parties stipulated and the Court ordered to continue the due date of Comcast's response to Plaintiff's Complaint from December 26, 2013 to January 29, 2014. Dkt. No. 4.

(2) On July 11, 2014, the parties stipulated and the Court ordered to continue the settlement conference from August 7, 2014 to October 31, 2014. Dkt. No. 31.

(3) On September 17, 2014, the parties stipulated and the Court ordered to continue the settlement conference from October 31, 2014 to December 1, 2014. Dkt. No. 37.

The extensions the parties seek in this stipulation will not have any adverse effect on the schedule for the case.

Daniel Ray Bacon and Troy Valdez declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on May 1, 2015.

IT IS SO STIPULATED.

IT IS SO ORDERED that