STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO OPPOSE DEFENDANT'S MOTION FOR PROTECTIVE ORDER PRECLUDING INAPPROPRIATE AREAS OF FED.R.CIV.P. 30(B)(6) EXAMINATION

FIRST REQUEST

GEORGE FOLEY, JR., Magistrate Judge.

Plaintiff DONNA CARLSON ("Plaintiff") and Defendants SAM'S WEST, INC. and SAM'S REAL ESTATE BUSINESS TRUST ("Defendants") by and through their respective counsel of record, do hereby stipulate to extend the time for Plaintiff to oppose Defendants' Motion for Protective Order Precluding Inappropriate Areas of FRCP 30(b)(6) Examination, by fourteen (14) days.

Pursuant to Local Rule 2.25, the parties hereby aver that this is the first request for such extension of time regarding Plaintiff's opposition to this motion.

The parties aver, pursuant to Local Rule 2.25, that good cause exists for the requested extension. It is Plaintiff's position that testimony from Defendant's 30(b)(6) representative is necessary to include in her opposition. That deposition occurred on May 22, 2018, the transcript from that deposition will most likely not be available until at least June 8, 2018.

PROPOSED NEW DEADLINE FOR PLAINTIFF'S OPPOSITION

Plaintiff's Opposition to Defendant's Motion for Protective Order

Hearing on Defendant's Motion for Protective Order

If this extension is granted, the hearing currently scheduled for June 14, 2018, at 10:30 a.m. regarding the oral arguments on this motion should be rescheduled to allow Defendants time to reply to Plaintiff's opposition.

The parties aver that this request for extension of time for Plaintiff's opposition to Defendants' Motion for Protective Order is made in good faith and not for the purpose of delay.

IT IS SO ORDERED