[PROPOSED] STIPULATED ORDER EXTENDING WHITTAKER'S DEADLINE TO RESPOND FOR ALL PENDING DISCOVERY AND DEFENDANT U.S.A.'S DEADLINE TO SEEK DISCOVERY RELIEF THERETO

EDWARD M. CHEN, District Judge.

STIPULATION

Plaintiff Whittaker Corporation ("Whittaker") and Defendant United States of America (collectively the "Parties") hereby enter into this stipulation ("Stipulation") and agree that Whittaker's deadline to respond to Defendant's pending written discovery requests will be extended to Monday, June 8, 2015. The currently pending discovery requests encompassed by this stipulation are: Defendant's Second Set of Requests for Admission to Plaintiff Whittaker Corporation served on April 24, 2015, Defendant's Third Set of Requests for Admission to Plaintiff Whittaker Corporation served on April 29, 2015, Defendant's Third Set of Requests for Production to Plaintiff Whittaker Corporation served on April 29, 2015, and Defendant's Third Set of Interrogatories to Plaintiff Whittaker Corporation served on April 29, 2015 (collectively, "Covered Discovery").

Because this extension will result in service of Whittaker's responses to the Covered Discovery being served after the May 29, 2015 fact discovery cut-off, to accommodate Local Rule Civ. 37-3, the Parties agree and seek Court approval to extend Defendant's deadline to seek discovery relief from the Court pursuant to Judge Chen's Civil Standing Order on Discovery until seven (7) days after Whittaker serves its responses, or until June 15, 2015.

NOW, THEREFORE, the Parties stipulate, by and through their undersigned counsel of record, as follows:

1. Whittaker shall respond to the Covered Discovery no later than June 8, 2015, and

2. Defendant may seek any necessary discovery relief from the Court pursuant to Judge Chen's Civil Standing Order on Discovery no later than seven (7) days after Plaintiff serves its responses, or no later than June 15, 2015.

IT IS SO STIPULATED:

PURSUANT TO STIPULATION, IT IS SO ORDERED.