The opinion of the court was delivered by: Dennis L. Beck United States Magistrate Judge
JOINT STIPULATION FOR EXTENSION OF LITIGATION DEADLINES AND SCHEDULING ORDER
LaMonte Tumbling ("Plaintiff") and Merced Irrigation District ("Defendant"), by and through their respective attorneys of record, hereby stipulate to and request the Court enter a scheduling order revising the amended scheduling order entered by this court on December 4, 2009. (See Joint Stipulation and Order attached as Exhibit A).
The revisions to the scheduling order are as follows:
(a) Extend the completion date for the taking of the non-expert deposition of Trudy Largent by 60 days from February 15, 2010, to April 15, 2010.
(b) Extend the completion date for the taking of the non-expert depositions of Cindy LaCava and Jem Brown by 30 days from February 15, 2010, to March 17, 2010.
Good cause exists to extend the deposition discovery deadline for Trudy Largent by 60 days in light of:
(a) The difficulty Plaintiff is having in obtaining the report conducted and submitted by Mrs. Largent regarding the complaints of harassment against Mr. Tumbling by Ms. Cindy LaCava and Ms. Linda Davidson.
(b) MID is in possession of this report, yet it has not been produced to Plaintiff. Plaintiff is therefore prevented from preparing and conducting an informed and effective deposition of Trudy Largent until such time the report is produced.
Good cause exists to extend the deposition discovery deadline for Cindy LaCava and Jem Brown by 30 days in light of:
(a) The fact that Jem Brown lives in Wisconsin and, although the parties have started his deposition, his schedule has made it difficult to find sufficient time to complete his deposition. The parties do not believe the schedule of Mr. Brown and counsel for the parties will make it possible to complete his deposition before February 15, 2010.
(b) The parties have begun the deposition of Cindy LaCava, but recent scheduling conflicts with other deponents have necessitated rescheduling Ms. LaCava's deposition. Counsel for the parties do not believe it will be possible to reschedule Ms. LaCava's deposition prior to February 15, 2010.
For these reasons, the parties respectfully request the Court modify the Pre Trial Scheduling Order so that it conforms to the foregoing new discovery cut-off dates for the deposition of Trudy Largen, Cindy LaCava, and Jem Brown.
Date: __February 10, 2010 MURRAY & ASSOCIATES DALEY & HEFT Lawrence D. Murray Neal S. Meyers Attorney for ...