1 GJALMYENSN M &. FHIANNLLEOYN, L, LJRP. , Bar No. 214096 2 BRANDON P. RAINEY, Bar No. 272341 One Walnut Creek Center 3 100 Pringle Avenue, Suite 500 Walnut Creek, CA 94596 4 Telephone: (925) 210-2800 Facsimile: (925) 945-1975 5 Attorneys for Defendants 6 Haier US Appliance Solutions, Inc., d/b/a GE Appliances, and 7 Home Depot USA, Inc.

8 UNITED STATES DISTRICT COURT

9 EASTERN DISTRICT OF CALIFORNIA

10 ) Case No. 2:20-cv-00210-TLN-DB 11 ROLANDO MUNOZ and JOANNA ) FRAIRE, ) STIPULATION TO CONTINUE 12 ) DISCOVERY DEADLINES; ORDER Plaintiffs, ) 13 ) vs. ) 14 ) HOME DEPOT USA, INC.; HAIER US ) 15 APPLIANCE SOLUTIONS, INC. dba GE ) APPLIANCES, and DOES 1 to 50, ) 16 inclusive, ) ) 17 Defendants. ) ) 18

19 TO THE COURT, THE PARTIES AND THEIR ATTORNEYS OF RECORD:

20 PLEASE TAKE NOTICE that, pursuant to Local Rule 143, Plaintiffs Rolando Munoz

21 and Joanna Fraire and Defendants Haier US Appliance Solutions, Inc., d/b/a GE Appliances and

22 Home Depot USA, Inc. have stipulated to continue the fact discovery, expert disclosure and

23 rebuttal expert designation deadlines in this matter. (Dkt. 9.) Good cause exists for the

24 extension of those deadlines as a result of the coronavirus public health crisis, which has limited

25 and will continue to limit the parties’ abilities to conduct discovery. See Fed. R. Civ. P. 16(b);

26 Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992). More particularly,

27 the pandemic has prevented the parties and their experts from conducting an examination of the

28 range that allegedly “exploded” and injured Plaintiffs, which examination must be conducted 1 2 the parties anticipate that the stipulated extensions will allow them to conduct and complete

3 discovery in an orderly and efficient manner (subject, of course, to further pandemic-related

4 disruptions).

5 Therefore, the parties respectfully request that the Court modify the existing deadlines

6 such that fact discovery will close on May 26, 2021, expert disclosures will be made by July 16,

7 2021, and rebuttal experts will be designated by August 25, 2021.

8 Dated: October 2, 2020 GLYNN & FINLEY, LLP 9 JAMES M. HANLON, JR.

BRANDON P. RAINEY 10 One Walnut Creek Center 11 100 Pringle Avenue, Suite 500 Walnut Creek, CA 94596 12 By: /s/ Brandon P. Rainey 13 Attorneys for Defendants

14 Home Depot USA, Inc. and Haier US Appliance Solutions, Inc., d/b/a GE 15 Appliances

16 Dated: October 2, 2020 BOHM LAW GROUP, INC. 17 LAWRENCE A. BOHM VICTORIA L. GUTIERREZ 18 4600 Northgate Boulevard, Suite 210

19 Sacramento, CA 95834

20 By: /s/ Victoria L. Gutierrez Attorneys for Plaintiffs 21 Rolando Munoz and Joanna Fraire

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28 / / / 1 2 Good cause having been established to continue the discovery deadlines in this matter

3 (Dkt. 9), the Court hereby GRANTS the parties’ stipulation. Fact discovery will close on

4 May 26, 2021; expert disclosures will be made by July 16, 2021; and rebuttal experts will be

5 designated by August 25, 2021.

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7 IT IS SO ORDERED.

8 DATED: October 5, 2020

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