STIPULATION AND ORDER REGARDING EXTENSION OF EXPERT DISCLOSURE AND DISCOVERY DEADLINES

CAROLYN K. DELANEY, Magistrate Judge.

THE PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, STIPULATE AS FOLLOWS:

Pursuant to Federal Rule of Civil Procedure 16 and this Court's Status (Pretrial Scheduling) Order (ECF 24), the parties hereby stipulate and propose to continue the current dates for initial expert disclosures by approximately forty-five (45) days, as well as the due date for rebuttal expert disclosures and for the completion of discovery, as further set forth below. The parties do not request a continuance of the trial date or of any other dates at this time.

The Court previously granted a stipulation and proposed order extending these dates from January 15, 2016, to March 15, 2016. (See Dkt. No. 30). The parties seek this further extension to provide time to complete the core fact discovery needed for expert reports, including the deposition of a witness in Florida on March 30, 2016. Rather than have initial reports and one or more supplements, it is more efficient to extend the due date for expert reports at this time. The parties seek a corresponding continuance for rebuttal reports, and the discovery cut-off, to permit expert depositions in the early fall instead of the late summer in keeping with counsel's respective trial and personal calendars.

Thus, the parties hereby stipulate and propose that the current pre-trial dates be revised as follows:

The parties do not request any alteration of other dates at this time, and expect to be able to proceed on the current post-discovery schedule. Because this stipulation does not seek to alter the trial date, it "may be heard and decided by the assigned Magistrate Judge." (ECF 24 at 5:9). Respectfully submitted,

Good cause appearing, IT IS SO ORDERED.