Ireland v. Flowserve Corp.

Opinion

JKaenveilnle P J.. LSeaeh o(Sutraiate ( SBtaart eN Boa. r2 9N6o3. 4235)3 699) 50 California Street, 9th Floor San Francisco, California 94111-4615 Telephone: (415) 394-9400 Facsimile: (415) 394-9401 E-mail: Janelle.Sahouria@jacksonlewis.com E-mail: Kevin.Lee@jacksonlewis.com

Attorneys for Defendants FLOWSERVE CORP. and UNITED STATES DISTRICT COURT EASTERN DISTRICT JOHN IRELAND, Case No. 2:24-CV-01663-DJC-JDP Plaintiff, STIPULATION AND ORDER TO v. EXTEND DISCOVERY SCHEDULING FLOWSERVE CORP, FLOWSERVE US INC. and Does 1 to 10, (SECOND REQUEST)

Defendants. Complaint Filed: 04/03/2024 Trial Date: 06/01/2026 Plaintiff John Ireland (“Plaintiff”), by and through his counsel of record and Defendants Flowserve Corporation and Flowserve US, Inc. (“Defendants”), by and through their counsel of record, hereby stipulate and agree to extend the discovery deadlines as set forth below. This is the parties’ second request for an extension of the discovery deadline. 1. Discovery Completed to Date To date, the parties have completed their FRCP 26(f) conference and have made exchanged initial disclosures pursuant FRCP 26(a)(1). The parties have also conducted depositions of key witnesses, including Plaintiff. 2. Discovery Which Still Needs to Occur The parties have exchanged written discovery, but there remains additional discovery to be the reduction in force and Plaintiff’s inclusion in the reduction in force and termination. Defendant has also taken Plaintiff’s deposition, but Defendant has not yet completed Plaintiff’s deposition as Plaintiff has represented he has not completed a full investigation and search for responsive documents pertaining to his claimed damages. The parties have been diligently attempting to resolve and have agreed to engage in mediation with mediator Mark LeHocky. The parties are conferring on dates for an October mediation. 3. Proposed Schedule for Completing Remaining Discovery The parties propose extending the following deadlines to complete discovery: - Initial Expert Disclosures: November 7, 2025 - Rebuttal Expert Disclosures: November 21, 2025 - Expert Discovery Deadline: February 1, 2026 - Dispositive Motion Deadline: January 9, 2026 - Hearing on Dispositive Motions: February 19, 2026, at 1:30 PM Trial is currently scheduled for June 1, 2026. 4. Good Cause Supports the Request to Extend the Deadline as Set Forth Herein When a stipulation requires the modification of the scheduling order, the parties must first satisfy the “good cause” standard established by Rule 16(b). See Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 608 (9th Cir. 1992); see also Fed. R. Civ. P. 16(b)(4) (“A schedule may be modified only for good cause and with the judge’s consent”). The good cause inquiry is focused on the movant’s reasons for seeking to modify the scheduling order and primarily considers the movant’s diligence. In re W. States Wholesale Nat. Gas Antitrust Litig., 715 F.3d 716, 737 (9th Cir. 2013). The key determination is whether the subject deadline “cannot reasonably be met despite the diligence of the party seeking the extension.” Johnson, 975 F.2d at 609. Good cause supports the parties’ request to extend the Fact Discovery deadline. The parties have been diligent in pursuing discovery since the case’s removal to federal court, including holding their FRCP 26(f) conference, exchanging initial disclosures, and exchanging initial written discovery. However, the parties require additional time to engage in mediation and, if mediation By entering into this Stipulation, the Parties are not waiving any rights or objections they may have regarding any other party’s anticipated or actual discovery activities or conceding that any such discovery is proper or necessary. Nonetheless, they are entering into this stipulation in good faith and will address any disputes in the ordinary course. The Parties hereby stipulate to the aforementioned. Dated: August 29, 2025 HENRY LACEY By /s/ Stephen Henry Attorney for Plaintiff

Dated: August 29, 2025 JACKSON LEWIS P.C. By: /s/ Kevin P. Lee Janelle J. Sahouria Kevin P. Lee JACKSON LEWIS P.C. Attorneys for Defendants FLOWSERVE CORP. and FLOWSERVE US INC.

IT IS SO ORDERED:

Dated: August 29, 2025 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE