STIPULATION & [PROPOSED] ORDER EXTENDING TIME TO COMPLETE NOTICED DEPOSITIONS

EDWARD J. DAVILA, District Judge.

Plaintiff SAEED YOUSUF and Defendants ROBERT A. BOTHMAN, INC., ROBERT A. BOTHMAN, INC., Stakeholder Equity Participation Plan, and ROBERT A. BOTHMAN INC. Deferred Compensation Plan, an ERISA Pension or Trust (collectively referred to as the "Parties), through their respective counsel, hereby stipulate as follows:

WHEREAS, on January 25, 2017, the Parties filed their Joint Case Management Statement setting forth discovery cut-off dates [Dkt. 19]; and

WHEREAS, on March 31, 2017 this Court issued an Order setting forth the requested discovery cut-offs, including ordering that fact discovery was to be completed by January 1, 2018 [Dkt. 25]; and

WHEREAS, on November 22, 2017, the parties filed a Joint Stipulation asking the Court to appoint a Court-sponsored mediator [Dkt. 43]; and

WHEREAS, the parties have diligently been pursuing discovery, including propounding and responding to requests to produce, requests to admit, interrogatories, and issuing deposition notices for Plaintiff Saeed Yousuf and Defendant witnesses Robert Bothman and John Fox; and

WHEREAS, on November 28, 2017, the Court issued an order appointing W. George Wailes as mediator [Dkt. 45]; and

WHEREAS, no trial date is currently on calendar [Dkt. 25];

THEREFORE, in order to reduce potential litigation costs and allow mediation to occur before depositions move forward, the Parties hereby stipulate as follows:

[1.] The Court shall issue a Stipulated Order allowing the parties to take the currently noticed depositions of Saeed Yousuf, Robert Bothman, and John Fox after the close of discovery after mediation in front of W. George Wailes is concluded;

[2.] The current Fact Discovery Cutoff of January 1, 2018 shall remain intact.

[PROPOSED] ORDER

Counsel for the Parties in the above-captioned action submitted a Joint Stipulation to allow the currently noticed depositions of Saeed Yousuf, Robert Bothman, and John Fox to go forward after the close of fact discovery, currently set for January 1, 2018, pending completion of mediation. All other dates, including the January 1, 2018 close of discovery, set by this Court's Case Management Order of March 31, 2017 shall remain. [In addition, the Court makes the further orders stated below:]

IT IS SO ORDERED.