STIPULATION TO ALLOW THE TAKING OF FACT DEPOSITIONS BEYOND THE FACT DISCOVERY DEADLINE OF NOVEMBER 11, 2019 AND [PROPOSED] ORDER

CHARLES R. BREYER, District Judge.

Sabrina Shafer ("Shafer") and Skyline Advanced Technology Services, Michael Zanotto, Robert Bernosky, Rodney Guenther, and Devin Mauldin (collectively the "Skyline Parties"), by and through their respective counsel, stipulate to allow the taking of fact depositions beyond the fact discovery deadline of November 11, 2019. The parties state as follows:

1. WHEREAS, the deadline for the completion of fact discovery is November 11, 2019. (ECF No. 33 and ECF No. 59, for case 18-cv-6641 and 19-cv-787, respectively);

2. WHEREAS, the parties anticipate at least eight depositions and require additional time to coordinate witness availability (including several third parties) and to take the depositions;

3. WHEREAS, the parties continue to believe that mediation will be most effective following depositions;

4. WHEREAS, the parties seek the court's approval to allow them to complete fact depositions after the November 11, 2019 deadline for the completion of fact discovery and to move the Further Case Management Conference to January 17, 2020;

5. The parties have conferred and have agreed to seek approval to complete fact depositions by December 31, 2019. The parties have conferred but have not reached an agreement at this time to seek an extension of written discovery beyond the November 11, 2019 deadline;

6. No prior extensions of time relating to the fact discovery deadline have been requested or granted;

7. The requested extension will impact the following deadlines currently set for the case (ECF No. 33 and ECF No. 59, for case 18-cv-6641 and 19-cv-787, respectively):

THEREFORE, IT IS HEREBY STIPULATED by and between Shafer and the Skyline Parties that the parties will have until December 31, 2019 to complete fact depositions and that the Further Case Management Conference currently set for 12/6/19 will be moved to January 17, 2020 (or the next available date thereafter).

IT IS SO STIPULATED.

FILER'S ATTESTATION

I, Carlton Odim, am the ECF User whose identification and password are being used to file this Stipulation and [Proposed] Order. I hereby attest under penalty of perjury that 1) the content of this document is acceptable to all persons required to sign the document; 2) Defendants' Counsel Nathaniel Lipanovich counsel has concurred with the filing of this document, and 3) a record supporting this concurrence is available for inspection or production if so ordered.

ORDER

Pursuant to the parties' stipulation, IT IS SO ORDERED:

1. That the parties will have until December 31, 2019 to complete fact depositions;

2. Joint Case Management Statement due by January 3, 2020;

3. Further Case Management Conference set for January 17, 2020 at 8:30 AM in San Francisco, Courtroom 06, 17th Floor.