JOINT STIPULATION TO EXTEND DEADLINES

WILLIAM H. ORRICK, District Judge.

Pursuant to Local Rule 6-2 and 7-12, Plaintiff John Moffett and Defendants Zimmer, Inc., Zimmer Holdings, Inc., and Zimmer Orthopedic Surgical Products, Inc. (collectively, the "Parties") hereby stipulate, through their undersigned counsel of record, to an extension of the discovery deadlines in this case. In support of this stipulation, the parties state as follows:

1. The Court entered the Civil Pretrial Order (the "Order") on December 23, 2014, which sets forth the current case schedule in this matter (Doc. 28). The Court also set a mediation deadline of November 15, 2015, in civil minutes entered on December 16, 2015 (Doc. 27). The Parties respectfully seek a brief extension of the discovery and mediation deadlines in this case. The Parties do not seek to alter the deadline for dispositive motions or the pretrial conference date.

2. This is the Parties' first stipulation or request to extend the deadlines and is made in order to allow the Parties additional time to conduct and exchange discovery, collect all relevant medical records, and issue expert reports necessary to collectively evaluate their cases. Furthermore, mediation has a greater possibility of being productive once additional fact discovery has been completed in this case and the parties have begun to develop their arguments and defenses.

3. This request is made for good cause and not made for the purposes of delay or to prejudice any party, but in the interests of justice and for the purposes of an efficient and cost-effective potential resolution of this case.

NOW THEREFORE, the Parties, through their counsel of record, hereby STIPULATE and AGREE that the deadlines in the Order are amended as follows:

The undersigned attests that concurrence in the filing of the document has been obtained from each of the signatories.

ORDER

Pursuant to the Stipulation, IT IS HEREBY ORDERED THAT the deadlines in this case are amended as requested by the Parties above.