STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT AND DISCOVERY DATES AS MODIFIED

KANDIS A. WESTMORE, Magistrate Judge.

This case involves alleged violations related to storm water pollution statutes and regulations. The parties are engaged in settlement discussions and to that end, on September 14, 2016, they participated in a conference call with this Court's ADR Program Case Administrator. The parties have requested the assistance of a Magistrate Settlement Judge. The ADR facilitator indicated she would recommend that the Court assign this case to either a Magistrate Settlement Conference Judge or a mediator. Due to the Court's congested calendar, in either event, it appears that the settlement conference or mediation will not take place until December, 2016 or later.

The parties wish to preserve the resources necessary to settle the case, rather than spend them on case management and discovery procedures. Accordingly, the parties are requesting a continuance of all current deadlines to allow them to complete either a settlement conference or a mediation within the next 120 days.

Accordingly, the parties hereby request the Court enter an order as follows:

(1) The parties shall exchange the initial disclosures required under Federal Rule of Civil Procedure 26(a)(1) no later than February 15, 2017, as agreed upon by stipulation of the parties.

(2) Both plaintiff and defendants shall serve their first interrogatories, requests for production of documents and requests for admission pursuant to Federal Rules of Civil Procedure 33, 34 and 36, respectively, no later than March 20, 2017.

(3) Both plaintiff and defendants shall serve their first notices of deposition, pursuant to Federal Rule of Civil Procedure 30, no later than April 18, 2017. Plaintiff anticipates deposing:

1. Germon Medeiros

2. Person most knowledgeable for Sonoma Soil Builders, Inc.

3. Other witnesses that may be identified in the foregoing deposition and document discovery as possessing relevant information, for which leave of court under Federal Rule of Civil Procedure 30(a)(2) will be sought.

Defendants anticipate deposing individuals identified in discovery or at least one representative from plaintiff.

(4) Depositions of the parties shall commence after July 17, 2017, at mutually convenient dates and times.

(5) Both plaintiff and defendants shall serve subpoenas upon any third party witnesses no later than August 21, 2017, seeking the production of documents and/or depositions.

(6) Plaintiff shall serve its experts' reports upon defendants, pursuant to Federal Rule of Civil Procedure 26(a)(2), no later than October 23, 2017. The reports shall set forth the facts on which the expert relies and the process of reasoning by which the expert's conclusions are reached.

(7) Defendants shall serve their experts' rebuttal reports upon plaintiff, pursuant to Federal Rule of Civil Procedure 26(a)(2), no later than November 27, 2017.

(8) Depositions of the experts shall commence no later than December 11, 2017 for plaintiff's experts and January 22, 2018 for defendants' experts.

(9) All discovery shall be complete by February 19, 2018.

(10) The parties reserve the right to seek or to schedule additional discovery as may become necessary, so long as it is completed by March 19, 2018.

In addition, the Case Management Conference will be continued to January 24, 2017.

ORDER

IT IS SO ORDERED.