Stowe

INTRODUCTION

17 The parties, Plaintiff Kristopher Stowe (“Plaintiff”) and Defendant Brad Alford 18 (“Defendant”), through their respective attorneys of record, hereby jointly stipulate to modify the 19 motion briefing deadlines as set forth below.

RECITAL/GROUNDS FOR RELIEF

21 Pursuant to Rule 16, a party may seek modification of a scheduling order, including 22 modification of a discovery cut-off date, “only for good cause and with a judge’s consent.” Fed. 23 R. Civ. P. 16(b)(4). Rule 16(b)’s good cause inquiry focuses primarily on the movant’s diligence. 24 Coleman v. Quaker Oats Co., 232 F.3d 1271, 1294 (9th Cir. 2000). However, the court has 25 “broad discretion in supervising the pretrial phase of litigation.” Zivkovic v. S. Cal. Edison Co., 26 302 F.3d 1080, 1087 (9th Cir. 2002). A party may establish good cause by showing: (1) the [the 27 parties were] diligent in assisting the court in creating a workable Rule 16 order; (2) that [the 28 parties’] noncompliance with a Rule 16 deadline occurred or will occur, notwithstanding [their] diligent efforts to comply, because of the development of matters which could not have been reasonably foreseen or anticipated at…