Bryant v. Rubrik, Inc.

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Joel P. Waelty (SBN 226728)
LAW OFFICES OF JOEL P WAELTY
2030 N. Pacific Ave, Ste D
Santa Cruz, CA 95060
Tel.: (408) 752-2003
Fax: (408) 290-8992
E-Mail: ioel@waeltylaw.com
6 	Attorneys for Plaintiff
RICK BRYANT
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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
RICK BRYANT,
Plaintiff,
V.
RUBRIK, INC.,
Defendant.
) 	No. 5:25-cv-07989-SVK
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STIPULATION TO EXTEND
DISCOVERY DEADLINE TO
ACCOMMODATE THIRD PARTY
DEPOSITIONS
Plaintiff Rick Bryant, by and through his counsel Joel P. Waelty, and Defendant
17 Rubrik, Inc., by and through its counsel David A. Crane, hereby stipulate as follows:
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RECITALS
WHEREAS,
1. The operative scheduling order in this action sets the close of fact discovery on
21 November 13, 2026.
22 2. Plaintiff represents that he has served subpoenas to testify at deposition upon third-
23 party witnesses Mayo Clinic (Rule 30(b)( 6) designated representative) and Heather
24 Costa, an individual non-party, both issued on September 9, 2026, with depositions
25 noticed for October 2, 2026 and October 1, 2026, respectively.
26 3. Counsel for Mayo Clinic and Heather Costa, Ashley Repp of Dorsey Whitney LLP,
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28 STIPULATION TO EXTEND THE DISCOVERY CUTOFF
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1 	has infonned Plaintiffs counsel that her office is not available to proceed with the
2 	depositions of either witness before the week of November 30, 2026.
3 	4. The unavailability of counsel for third-party witnesses is an external scheduling
4 	constraint beyond the control of any party and constitutes good cause to extend the
5 	discovery cutoff as to these third-party depositions only. 	The testimony of these
6 	witnesses are considered by Plaintiff to be essential for the vindication of his rights
7 	because he asserts that their testimony is central to the reasons that Rubrik tenninated
8 	his employment. The parties have diligently pursued third-party discovery and the
9 	extension sought is the minimum necessary to accommodate counsel's availability.
10 	5. The parties agree that the extension requested herein is limited solely to completing
11 	the depositions of Mayo Clinic's Rule 30(b)(6) designee(s) and Heather Costa, and any
12 	associated document production obligations pursuant to the existing subpoenas, and
13 	shall not alter any other case management deadline, including but not limited to the
14 	expert disclosure schedule, dispositive motion deadlines, pretrial conference dates, or
15 	trial date, unless the Court orders otherwise.
16 	6. This is the first request to modify the discovery schedule in this action.
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18 	STIPULATION
19 	Based on the foregoing, the parties, through their respective counsel of record,
20 	HEREBY STIPULATE AND AGREE as follows:
21 	1. The deadline to complete third-party discovery, limited to the depositions of Mayo
22 	Clinic's Rule 30(b)(6) designated representative and Heather Costa and any document
23 	production required under the subpoenas served upon those witnesses, is extended from
24 	November 13, 2026 to December 21, 2026, or such other date as the Court deems
25 	appropriate.
26 	2. All other deadlines set forth in the operative scheduling order shall remain unchanged
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1 	and in full force and effect.
2 	3. The parties will cooperate in good faith to schedule the depositions of Mayo Clinic
3 	and Heather Costa at mutually convenient dates within the extended period, consistent
4 	with the availability of counsel for the witnesses.
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IT IS SO STIPULATED.
7 	DA TED: September 30, 2026
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11 	DATED: September 30, 2026
LAW OFFICES OF JOEL P. WAELTY
By: 	Isl Joel P. Waelty
Joel P. W aelty
Attorney for Plaintiff RICK BRYANT
MAYNARD NEXSEN LLP
By: 	Isl David A. Crane
Thy B. Bui
David A. Crane
Attorneys for Defendant RUBRIK, INC.
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1 	[PROPOSED)ORDER
2 	The Court, having reviewed the foregoing Stipulation of the parties and finding
3 	good cause therefor, hereby ORDERS as follows:
4 	1. The deadline to complete third-party discovery, limited to the depositions of Mayo
5 	Clinic's Rule 30(b)(6) designated representative and Heather Costa and any document
6 	production required under the subpoenas previously served upon those witnesses, is
7 	extended to December 21, 2026 ________________ .
8 	2. All other deadlines established in the Court's scheduling order remain in full force
9 	and effect.
10 	3. The parties shall complete the depositions ofMayo Clinic and Heather Costa no later
11 	than the new discovery cutoff, absent further order of the Court.
12 	IT IS SO ORDERED.
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Dated: _____, 2026 Hon. Susan van Keulen United
States Magistrate Judge
Northern District of California
STIPULATION TO EXTEND THE DISCOVERY CUTOFF
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