STIPULATION ON SCHEDULING AND ORDER

HAYWOOD S. GILLIAM, JR., District Judge.

Pursuant to the Court's January 16, 2019 Order (Dkt. 28), the parties conferred by phone and e-mail. Plaintiffs Gary Jacobs,et al., ("Plaintiffs") and Defendants City of Belmont, California and Belmont Fire Protection District ("Defendants"), by and through their respective counsel, do hereby submit this Stipulation on Scheduling and Proposed Order. After conferring, counsel for the parties have agreed upon the following:

(1) Mediation

The parties intend to engage in mediation with a private mediator jointly selected by the parties. The parties intend to complete mediation no later than April 1, 2019. However, if it is not possible to complete mediation by this date due to the mediator's schedule, the parties may request an additional 30-day extension of the subsequent discovery deadlines proposed herein.

The parties will agree to engage in limited, damages-based discovery in order to be able to meaningfully participate in mediation.

(2) Full Fact Discovery

The parties will serve initial Notices of Deposition, Requests for Admission, Interrogatories, and Requests for Production of Documents within 14 days of the conclusion of mediation and no later than April 15, 2019.

(3) Suggested Discovery Cut-Off

The parties propose that the completion of fact discovery, including expert discovery, by July 15, 2019.

(4) Expert Discovery

Plaintiff's expert witness disclosure and report will be due on June 17, 2019. Defendant's expert witness disclosure and report will be due on July 1, 2019. The expert deposition deadline will be July 15, 2019.

(5) Dispositive Motions

The parties anticipate that dispositive motions may be filed after discovery is completed. The Parties propose that notice of a dispositive motion be filed by September 5, 2019, and a hearing for dispositive motions be set for October 17, 2019.

(6) Pre-Trial Conference

The parties propose that the Pre-Trial Conference in this case take place on January 14, 2020.

(7) Trial

Based on the Court's January 16, 2019 Order (Dkt. 28), the Parties propose a trial date of January 29-31, 2020. Trial of this case will by jury. The parties estimate that trial of this case will take two (2) to three (3) days.

IT IS SO STIPULATED AND REQUESTED.

PURSUANT TO STIPULATION, IT IS SO ORDERED except, the jury trial will start on Monday, January 27, 2020 at 8:30 a.m. (for three days).