STIPULATION TO EXTEND DISCOVERY DEADLINE; [PROPOSED] ORDER

RONALD M. WHYTE, District Judge.

Pursuant to Federal Rules of Civil Procedure, Rule 29, and Civil Local Rules 6-2 and 7-12, Plaintiff, Shiow-Huey Chang, and Defendants hereby request an extension of the fact discovery cut-off in this case. Under the Order After Initial Case Management Conference, the current fact discovery deadline is November 25, 2015. The parties request the deadline be extended to February 18, 2016.

REASONS FOR ENLARGEMENT OF TIME

This action commenced on June 5, 2015. Defendants filed an answer to the complaint on July 1, 2015. The Initial Case Management Conference ("initial CMC") was held on September 14, 2015.

The parties sought discovery at their earliest opportunity, and discovery has continued in earnest. Pursuant to the Court's order following the initial CMC, fact discovery is scheduled to close next month. However, the parties believe their preparation for trial would benefit from additional time to conduct fact discovery.

In addition, during discovery, plaintiff has ascertained the names of percipient witnesses, all employees or former employees of the defendant County of Santa Clara. An enlargement of the deadline to complete discovery will allow the parties to select deposition dates convenient to counsel and the witnesses.

Lastly, this matter is scheduled for a settlement conference before Magistrate Nathanael Cousins on December 8, 2015. The parties would like to reserve the possibility to conduct discovery after the settlement conference, and thereby conserve resources in the event the matter settles in December.

ALL PREVIOUS TIME MODIFICATIONS

There have been no time modifications in this case to date.

EFFECT OF REQUESTED TIME MODIFICATION

This request would have no effect on other deadlines previously set by the Court.

PURSUANT TO STIPULATION, IT IS SO ORDERED.