The opinion of the court was delivered by: Gary S. Austin United States Magistrate Judge
AMENDED STIPULATION TO EXTEND EXPERT AND FACT DISCOVERY DEADLINES; DECLARATION OF JESSICA S. DIOTALEVI; ORDER THEREON
Whereas, the Court issued a Scheduling Conference Order on September 17, 2012, setting a 20 trial date and expert and fact discovery deadlines. (Declaration of Jessica S. Diotalevi ("Diotalevi 21 Decl.") at ¶ 4. 22 Whereas, the pretrial conference is set for September 4, 2013 and trial is set for October 29, 2013 (Diotalevi Decl. at ¶ 4).
Whereas, there is good cause for continuing the expert and fact discovery deadlines set forth
25 in the Scheduling Conference Order (Diotalevi Decl. at ¶ 5). The parties have worked diligently to 26 conduct discovery in this matter but have not yet completed sufficient discovery in this matter to 27 obtain experts. Id. The parties have propounded and responded to initial written discovery and have deposed the employee who conducted the hearing test on plaintiff. Id. Plaintiff's deposition was 2 initially set for November 5, 2012. Id. Due to scheduling conflicts, the parties continued Plaintiff's 3 deposition to January 23, 2012. Id. Once the parties depose Plaintiff, they will conduct further fact 4 discovery including additional witnesses from Defendants Siemens and Costco and retain experts. Id. 5
True and correct copies of the two notices of Plaintiff' deposition are attached hereto as group 6
Whereas, the parties request only to extend the expert and fact discovery deadlines but leave
8 the pretrial motion filing and motion deadlines in place (Diotalevi Decl. at ¶ 6). 9
Whereas, there have been no prior requests for extending any deadlines in this matter (Diotalevi Decl. at ¶ 6). 11
Therefore, Plaintiff TED FAULKNER, Defendant SIEMENS CORPORATION, and Defendant COSTCO WHOLESALE CORPORATION have stipulated and agree to continue the 13 following dates: 14
1. The Initial Expert Disclosure is continued from December 12, 2012 to February 12, 2013.
2. The Supplemental Expert Disclosure is continued from January 9, 2013 to March 9, 2013.
3. The Non-expert Discovery Cutoff is continued to from February 15, ...