STIPULATION TO EXTEND DISCOVERY PLAN AND AMEND SCHEDULING ORDER

(First Request)

PEGGY A. LEEN, Magistrate Judge.

Plaintiffs, Robert and Myrna Danganan, by and through their attorney, and Defendant, American Family Mutual Insurance Company, by and through its attorney (hereinafter collectively referred to as "the Parties") hereby respectfully submit their Stipulation and Order to Extend Discovery Deadlines (First Request) pursuant to Rules 6(b) and 26(f) of the Federal Rules of Civil Procedure and Local Rules 6-1 and 26-4. The proposed extended discovery deadlines contemplate sixty (60) days to complete pending discovery.

This stipulation is brought pursuant to LR26-4, which provides that a request made within 21 days of the discovery cut-off date, which is currently set for May 11, 2018, must be supported by a showing of good cause. Good cause exists to support this request. In sum, the parties need additional time to depose pertinent witnesses. Defendant counsel sought to depose Plaintiffs on April 16, 2018. After serving notice for the proposed April 16, 2018 depositions of Plaintiffs, defendant's counsel was advised on March 30, 2018 that (i) Plaintiffs' counsel had a conflict with the April 16, 2018 deposition date and (ii) Plaintiffs would be out of the country from April 26, 2018 through May 22, 2018. Due to counsel's conflict, Plaintiffs' travel plans and other obligations, Plaintiffs' depositions were rescheduled for June 4, 2018. In the same vein, Plaintiffs' counsel sought to depose a corporate representative of Defendant. Plaintiffs' counsel noticed the Rule 30(b)(6) deposition of a corporate representative of Defendant for May 10, 2018 but, after servicing notice of the proposed May 10, 2018 deposition, defendant's counsel indicated that additional time was needed to identify and prepare the witness for the deposition. The Parties have not yet confirmed a new deposition date, but hope to do so shortly.

The Parties request this Stipulation to extend discovery by sixty (60) days be approved by the Court in order to accommodate the Parties in conducting the remaining discovery, including allowing Defendant to depose Plaintiffs and allowing Plaintiffs to depose Defendant.

This is the Parties' first request for an extension of time, and the same is not interposed for purposes of delay, but for the sole purpose of allowing to Parties to diligently and adequately prepare their respective cases for either settlement discussions or trial.

I. DISCOVERY COMPLETED

The Parties are scheduling the depositions of Plaintiff and Defendants.

II. DISCOVERY THAT REMAINS TO BE COMPLETED

Plaintiffs anticipate the taking of the depositions of American Family's 30(b)(6) Representative and its expert, and Defendant anticipates the taking of the deposition of Plaintiffs and their expert. Plaintiffs also anticipate serving written discovery upon Defendant.

III. REASON WHY DISCOVERY HAS NOT BEEN COMPLETED

The Parties have been diligent in conducting discovery but believe additional time is necessary for the Parties to complete additional depositions; for their experts to conduct expert discovery and complete their reports.

IV. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY

STIPULATED AND AGREED.

IT IS SO ORDERED.