STIPULATION AND ORDER TO EXTEND TIME FOR DISCLOSURES UNDER GENERAL ORDER 71

HAYWOOD S. GILLIAM, JR., District Judge.

WHEREAS General Order 71 requires the parties to produce certain documents and provide certain information to each other "within 30 days after the defendant has submitted a responsive pleading or motion, unless the assigned judge rules otherwise."

WHEREAS this case was removed to federal court from the Contra Costa County Superior Court on July 19, 2019.

WHEREAS Defendant filed its answer in state court on July 15, 2019, before either party was aware the case would be subject to General Order 71, and there will not be a responsive pleading or motion filed following removal.

WHEREAS the parties would like to start the 30 days to comply with General Order 71 from the day after the Court notified the parties of General Order 71.

WHEREAS documents and information have previously been exchanged between the parties in the state court action prior to removal, and the parties agree they need not produce documents and information that have already been exchanged in discovery proceedings in state court.

Pursuant to General Order 71, the Parties stipulate to an extension of time to provide documents and information in General Order 71 to August 23, 2019, and request Court approval of this deadline, and approval that the parties need not produce documents and information that have already been exchanged in discovery proceedings in state court.

FILER'S ATTESTATION

Pursuant to Civil Local Rule 5-1(i)(3), regarding signatures, Jason M. Sherman hereby attests that concurrence in the filing of this document has been obtained from all the signatories above.

PURSUANT TO STIPULATION, IT IS SO ORDERED.