JOINT STIPULATION TO CONTINUE CASE DEADLINES; [PROPOSED] ORDER

JON S. TIGAR, District Judge.

Plaintiff, Dennis M. Lorenz ("Plaintiff"), and Defendants, Safeway Inc. ("Safeway") and Safeway Benefit Plans Committee ("Benefit Plans Committee"), collectively ("Defendants"), through their counsel, hereby stipulate and agree that:

WHEREAS, Plaintiff filed a complaint against Defendants and Great-West Financial RPS LLC ("Great-West") on August 25, 2016;

WHEREAS, Plaintiff filed an Amended Complaint on September 16, 2016 (Docket No. 7);

WHEREAS, Plaintiff filed a Second Amended Complaint on November 21, 2016 (Docket No. 31);

WHEREAS, the Court dismissed the claims against Great-West with prejudice and consequently removed Great-West as a defendant in this action on March 13, 2017 (Docket No. 58);

WHEREAS, Plaintiff filed a Third Amended Complaint on March 31, 2017 (Docket No. 66);

WHEREAS, after the Court found this matter to be related to the case of Maria Karla Terraza v. Safeway Inc., et al. (No. 16-cv-03994-JST) (see Docket No. 26), the Parties in this matter and Terraza streamlined their discovery process;

WHEREAS, the Parties Stipulated to Continue Case Deadlines, and this Court has entered orders continuing case deadlines on December 18, 2017 (Dkt. 79) and on February 21, 2018 (Dkt. 84);

WHEREAS, the Parties have exchanged initial disclosures, engaged in written discovery and exchange of documents, and will have taken 17 fact witness depositions on or before the current deadline to complete fact discovery on April 27, 2018;

WHEREAS, when the current deadline to complete fact discovery passes, three additional depositions will remain to be taken;

WHEREAS, because depositions will remain outstanding when the current deadline to complete fact discovery passes, the Parties will be unable to provide potential experts with all fact discovery relevant to the case when fact discovery closes;

WHEREAS, although the Parties have been working diligently and cooperatively in the discovery process and in preparing this case for trial, the Parties believe that, given the number of Defendants and the scope of discovery, including the necessity of taking 20 depositions in no less than five different states, the current schedule does not provide adequate time to complete discovery and exchange expert reports. The Parties therefore respectfully request that the Court continue the case deadlines as detailed below;

WHEREAS, the Parties have previously made two requests to extend the deadlines for completing discovery and filing dispositive motions, and the pretrial and trial dates (Dkts. 79, 84);

WHEREAS, the Parties do not propose any change in the trial schedule or the remainder of the pretrial schedule;

NOW, THEREFORE, the Parties, through their respective counsel, hereby stipulate, subject to the approval of the Court, to the following schedule:

IT IS SO STIPULATED.

[PROPOSED] ORDER

Good cause exists for an order continuing the deadlines for completing fact and expert discovery, including submitting expert disclosures and rebuttals, and filing dispositive motions to the following dates: