STIPULATION TO EXTEND SCHEDULED DEADLINES (SECOND REQUEST)

CAM FERENBACH, Magistrate Judge.

Pursuant to Local Rules IA 6.1 and 26-4, Plaintiff Cristian Garcia-Chavez and Defendants J.B. Hunt Transport Inc. and Orlando Johnson (collectively the "Defendants," and together with Plaintiff, the "Parties") hereby stipulate and agree to extend the deadlines set forth in the previously filed Joint Discovery Plan for a period sixty (60) days. This is the second stipulation to extend any deadline in this proceeding.

I. Discovery Completed to Date

To date, the Parties each propounded written discovery upon one another. Defendants served their responses to Plaintiff's written discovery on April 30, 2018. Plaintiff served his responses to Defendants' written discovery June 6, 2018. An independent medical examination of the Plaintiff was also conducted on June 8, 2018.

II. Discovery Yet to be Completed

Plaintiff's deposition is currently scheduled for June 20, 2018. Additionally, the Parties are still working to coordinate and schedule the depositions of (1) defendant Orlando Johnson, (2) a corporate designee of JB Transport, Inc., (3) many of Plaintiff's medical providers, and (4) Plaintiff's wife. As detailed below, the Parties have encountered numerous complications in scheduling the depositions of the medical providers. The Parties agree that additional discovery is necessary to clarify certain categories of damages claimed by Plaintiff. The Parties have also not exchanged expert reports or conducted any expert discovery to date. The Parties also will need to address any additional areas of discovery which become apparent through the course of discovery and litigation in this matter.

III. Necessity of Requested Extension of Time

While the Parties have exchanged responses to written discovery, additional discovery is necessary with respect to certain categories of damages claimed by Plaintiff. Such discovery may necessitate the retention of additional expert witnesses in this case. The current deadline for expert disclosures is July 9, 2018. Additionally, complications continue to exist in securing dates to depose several of the Plaintiff's medical health care providers. The current deadline to complete discovery is September 7, 2018. Due to these issues, the Parties believe a sixty (60) extension to all remaining deadlines is necessary. The Parties are confident the requested extension will provide a sufficient amount of time for the Parties to complete additional discovery as to the categories of damages claim by Plaintiff, identify all necessary expert witnesses, and schedule and complete all necessary depositions in this matter.

IV. Requested Modifications to the Scheduling Order

The Parties stipulate and agree to modify the Joint Discovery Plain as follows:

IT IS SO AGREED.

ORDER

IT IS SO ORDERED.