1 JAMES P. WAGONER (SBN 58553) [email protected] 2 LEJF E. KNUTSON (SBN 234203) [email protected] 3 MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP 7647 North Fresno Street 4 Fresno, California 93720 Telephone: (559) 433-1300 5 Facsimile: (559) 433-2300

6 Attorneys for Plaintiff TEDDI A. BRYSON 7 CHARLES K. CHINEDUH (SBN 273258) 8 [email protected] MAYNARD NEXSEN LLP 9 10100 Santa Monica Blvd., Suite 550 Los Angeles, California 90067 10 Telephone: (310) 596-4500 Facsimile: (205) 254-1999 11 Attorneys for Defendant 12 WEST COAST LIFE INSURANCE COMPANY

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14 UNITED STATES DISTRICT COURT 15 EASTERN DISTRICT OF CALIFORNIA 16

17 TEDDI A. BRYSON, an individual, Case No. 1:23-cv-00193-JLT-SKO

18 Plaintiff, STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER AS 19 v. TO EXPERT WITNESS DESIGNATION AND REBUTTAL 20 WEST COAST LIFE INSURANCE DESIGNATION COMPANY, a corporation, and 21 DOES 1-100, (Doc. 20)

22 Defendants.

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25 Plaintiff Teddi A. Bryson (“Plaintiff”) and Defendant West Coast Life 26 Insurance Company (“West Coast Life”) (collectively, the “Parties”), jointly 27 stipulate to an extension to designate expert witnesses until July 15, 2024, Rebuttal 28 1 Expert Disclosures to August 2, 2024, and the Expert Discovery cutoff to August 2 13, 2024. 3 In support of this request, the Parties state as follows: 4 1. When an act must be done within a specified time, the Court may, for 5 good cause, extend the time “with or without motion if the court acts, or a request is 6 made, before the original time expires.” Fed. R. Civ. P. 6(b)(1)(A). With respect to 7 an order setting forth the Court’s pretrial schedule, “[t]he district court may modify 8 the pretrial schedule if it cannot be reasonably met despite the diligence of the party 9 seeking the amendment.” Johnson v. Mammoth Recreations, Inc.,

, 609 10 (9th Cir. 1992) (internal quotation marks and citation omitted). 11 2. Good cause exists for the Parties’ requested extension. The parties will 12 be participating in a mediation on June 20, 2024. The parties would like to save the 13 time and expense of experts should the case be resolved at the mediation. The Parties 14 further agree that the continuance sought will not prejudice any party or result in 15 undue delay. 16 6. In connection with the requested extension, the Parties stipulate to the 17 following schedule regarding expert witnesses: 18 19 Event Current Deadline Proposed New Deadline 20 Non Expert Discovery March 6, 2024 July 4, 2024 21 Expert Disclosures February 21, 2024 June 20, 2024 July 15, 2024 22 July 11, 2024 Rebuttal Expert Disclosures March 13, 2024 23 August 2, 2024 August 6, 2024 24 Expert Discovery April 8, 2024 August 13, 2024 25 Non-Dispositive Motion April 15, 2024 August 13, 2024 Filing 26 Non-Dispositive Motion May 22, 2024 September 19, 2024 27 Hearing 28 1 Dispositive Pretrial Motion May 17, 2024 September 14, 2024 2 Filing 3 Dispositive Pretrial Motion June 24, 2024 October 22, 2024 Hearing 4 Deadline to Provide 5 Proposed Settlement July 17, 2024 November 14, 2024 6 Conference Dates 7 Pre-Trial Conference August 19, 2024 December 17, 2024 8 Trial October 15, 2024 February 12, 2025 9 10 WHEREFORE, in light of the foregoing and for good cause, the Parties, by 11 and through their respective counsel, hereby stipulate to the expert witness deadlines 12 as set forth in the above chart. 13 IT IS SO STIPULATED AND AGREED. Dated: June 25, 2024 MAYNARD NEXSEN LLP 14

15 /s/ Charles K. Chineduh By: CHARLES K. CHINEDUH 16 Attorney For Defendant WEST COAST LIFE INSURANCE 17 COMPANY

18 Dated: June 25, 2024 MCCORMICK, BARSTOW, 19 SHEPPARD, WAYTE & CARRUTH 20 LLP 21 By: /s/ James P. Wagoner 22 JAMES P. WAGONER 23 Attorneys for Plaintiff TEDDI A. BRYSON 24 25 Filer’s Attestation-Local Rule 131 26 The filing attorney attests that he has obtained concurrence regarding the filing of 27 this document and its content from the signatories to this document. 28 1 ORDER

2 Pursuant to the Stipulation of the Parties set forth above (Doc. 20), and for 3 good cause shown (see Fed. R. Civ. P. 16(b)(4)) the case schedule (Doc. 17) is 4 hereby MODIFIED as follows: 5

6 Event New Deadline 7 Expert Disclosures July 15, 2024 8 9 Rebuttal Expert Disclosures August 2, 2024 10 Expert Discovery August 13, 2024 11 12 All other dates set forth in the case schedule REMAIN as SET. 13 14 IT IS SO ORDERED.

15 Dated: June 25, 2024 /s/ Sheila K. Oberto . 16 UNITED STATES MAGISTRATE JUDGE

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