STIPULATION AND [PROPOSED] ORDER REVISING THE COURT'S SCHEDULING ORDER

RICHARD SEEBORG, District Judge.

TO THE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

This stipulation to revise the Court's June 30, 2016 Scheduling Order (Dkt. 16) in the above-referenced matter is made and entered into by and between plaintiff Jacqulyn Delaney and defendant State Farm Mutual Automobile Insurance Company ("State Farm"), referred to collectively as the "Parties."

I.

RECITALS

1. WHEREAS, on June 30, 2016, the Court issued its Scheduling Order (Dkt. 16), setting deadlines for fact discovery, expert discovery, and dispositive motions. The Scheduling Order set June 7, 2017, as the fact discovery cutoff and August 25, 2017, as the expert discovery cutoff.

2. WHEREAS, the Parties have not sought any prior extensions to the Court's June 30, 2016 Scheduling Order.

3. WHEREAS, the Parties desire to submit this matter to mediation.

4. WHEREAS, counsel for Delaney and State Farm have engaged in discussions to set the parameters for a possible settlement.

5. WHEREAS, the Parties believe that mediation would be more productive and more likely to settle the case if the Parties have additional time to conduct discovery and assess the merits of the case prior to the mediation.

6. WHEREAS, the Parties do not seek any extension of dates currently set by the Scheduling Order except for the fact discovery cutoff, expert disclosures, and expert discovery cutoff.

7. WHEREAS, the Parties have been working diligently toward moving this case forward in an efficient, expeditious manner. The Parties wish to litigate this matter in a cost-effective manner and avoid unnecessary attorneys' fees and costs.

8. WHEREAS, the Parties have tentatively agreed to hold the mediation session by June 30, 2017, subject to the Court's approval.

9. WHEREAS, the Parties have agreed to submit this Stipulation and [Proposed] Order to Revise the Court's Scheduling Order.

10. WHEREAS, the Parties hereby stipulate to revising the Court's June 30, 2016 Scheduling Order as follows.

II.

STIPULATION

Plaintiff and State Farm hereby stipulate and agree as follows:

1. The Parties agree to the following revisions to the Court's Scheduling Order:

IT IS SO STIPULATED.

Filer's Attestation: Pursuant to Civil Local Rule 5-1(i)(3), Jonathan K. Myers hereby attests that concurrence in the filing of this document has been obtained from each of the other signatories.

[PROPOSED] ORDER

Pursuant to the stipulated request by all Parties to this action and good cause appearing, the Court ORDERS the deadlines set by the Court's Scheduling Order continued as follows:

IT IS SO ORDERED.