[PROPOSED] STIPULATED ORDER RE: EXTENSION OF DEADLINE FOR EXPERT REPORTS

PEGGY A. LEEN, Magistrate Judge.

Plaintiffs Cung Le, Nathan Quarry, Jon Fitch, Brandon Vera, Luis Javier Vazquez, and Kyle Kingsbury ("Plaintiffs") and Defendant Zuffa, LLC ("Zuffa") (Zuffa and Plaintiffs collectively, "the Parties") having met and conferred on the issues addressed herein, respectfully submit the following [Proposed] Stipulated Order re: Extension of Deadline for Expert Reports:

WHEREAS, the Court issued the current Discovery Plan and Scheduling Order on October 14, 2016 (ECF No. 311), under which the deadline for Plaintiffs' opening expert class and merits reports is May 30, 2017, the deadline for Zuffa's opposing class and merits expert reports is July 24, 2017, and the deadline for Plaintiffs' rebuttal class and merits expert reports is September 5, 2017; and,

WHEREAS, Plaintiffs have asserted that several motions are currently pending whose outcomes could materially affect Plaintiffs' experts' opening reports, including:

WHEREAS, the Court has scheduled a hearing on Plaintiffs' motion for extension of discovery deadlines (ECF No. 363) and request for status conference (ECF No. 393) for June 1, 2017; and,

WHEREAS, the June 1 hearing would be two days after Plaintiffs' experts' opening reports are due; and,

WHEREAS, Plaintiffs have asked the Court to extend the expert reports deadline by at least sixty days (ECF No. 393 at 4); and,

WHEREAS, Zuffa has previously proposed to extend the expert reports deadline by 30 days or the later of the Court's ruling on Plaintiffs' Motion to Challenge Work Product Designation or Plaintiffs' motion to compel log of Dana White's cell phone communications (ECF No. 401 at 1);

WHEREAS, while Plaintiffs believe that the expert and other deadlines should be vacated pending further order of the Court, to avoid the uncertainties and inefficiencies that would result absent an agreement, and without prejudice to Plaintiffs' ability to seek additional time depending upon whether Plaintiffs are able to complete additional fact discovery as agreed by the parties and/or allowed by the Court, Plaintiffs have agreed to the deadlines set forth herein pending further order of the Court at the June 1 status conference; and,

WHEREAS, the Parties, having met and conferred on May 19, 2017, have agreed to the terms set forth in this Proposed Stipulated Order.

NOW THEREFORE, having considered the representations of the Parties, the Court hereby ORDERS:

The deadlines for the Parties' expert reports, including Plaintiffs' opening class and merits expert reports, previously set forth in the Court's Order dated October 14, 2016 (ECF No. 311), are hereby extended as follows:

IT IS SO ORDERED.