JOINT STIPULATION TO CONTINUE THE TRIAL DATE AND AMEND CASE MANAGEMENT SCHEDULING ORDER

RICHARD SEEBORG, District Judge.

JOINT STIPULATION

The Parties to the above-captioned action, through their respective counsel of record, hereby stipulate and agree to amend the Case Management Scheduling Order issued in this case as follows:

WHEREAS, the Court entered a Case Management Scheduling Order in the above-entitled matter on September 16, 2016;

WHEREAS, the Parties have diligently conducted discovery, including extensive oral and written discovery of at least fifteen oral depositions and thousands of produced documents, in order to prepare their cases and mutually understand the legal and factual issues in the case;

WHEREAS, the Parties intend to engage in private mediation on October 16, 2017;

WHEREAS, preparation for mediation will require substantial time and resources, thereby diverting attention and preparation from upcoming expert discovery deadlines;

WHEREAS, the Parties have agreed and request that this Court modify the Case Management Scheduling Order to continue the initial expert disclosure deadline from October 13, 2017 to October 20, 2017, the non-expert discovery deadline from October 20, 2017 to October 27, 2017, and the current trial date from February 26, 2018 to March 19, 2018, as set forth in the accompanying Proposed Revised Case Management Scheduling Order.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

The initial expert disclosure deadline in this matter will be continued from October 13, 2017 to October 20, 2017. The non-expert discovery deadline in this matter will be continued from October 20, 2017 to October 27, 2017. The trial date in this matter will be continued from February 26, 2018 to March 19, 2018.