Filed: Apr. 12, 2018
Latest Update: Apr. 12, 2018
Summary: SECOND STIPULATION AND JOINT REQUEST TO FURTHER MODIFY SCHEDULING ORDER TO EXTEND DISCOVERY CUT-OFF DATE; AND [PROPOSED] ORDER JON S. TIGAR , District Judge . IT IS HEREBY STIPULATED by and between the parties to this action, by and through their attorneys of record, and the parties jointly request that the Court modify its Scheduling Order, initially issued June 21, 2017 (Doc. No. 26) and modified on February 14, 2018 (Doc. No. 36) and March 12, 2018 (Doc. No. 39), to extend the deadline
Summary: SECOND STIPULATION AND JOINT REQUEST TO FURTHER MODIFY SCHEDULING ORDER TO EXTEND DISCOVERY CUT-OFF DATE; AND [PROPOSED] ORDER JON S. TIGAR , District Judge . IT IS HEREBY STIPULATED by and between the parties to this action, by and through their attorneys of record, and the parties jointly request that the Court modify its Scheduling Order, initially issued June 21, 2017 (Doc. No. 26) and modified on February 14, 2018 (Doc. No. 36) and March 12, 2018 (Doc. No. 39), to extend the deadline ..
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SECOND STIPULATION AND JOINT REQUEST TO FURTHER MODIFY SCHEDULING ORDER TO EXTEND DISCOVERY CUT-OFF DATE; AND [PROPOSED] ORDER
JON S. TIGAR, District Judge.
IT IS HEREBY STIPULATED by and between the parties to this action, by and through their attorneys of record, and the parties jointly request that the Court modify its Scheduling Order, initially issued June 21, 2017 (Doc. No. 26) and modified on February 14, 2018 (Doc. No. 36) and March 12, 2018 (Doc. No. 39), to extend the deadline for fact discovery as follows:
Event Scheduled Date Requested Date Previous Extension
Fact discovery cut-off April 30, 2018 June 8, 2018 2
Expert disclosures May 14, 2018 No change 2
Expert rebuttal May 28, 2018 No change 2
Expert discovery cutoff June 8, 2018 No change 2
Deadline to file dispositive June 21, 2018 No change None
motions
Pretrial conference statement Sept. 25, 2018 No change None
due
Pretrial conference Oct. 5, 2018 No change None
2:00 p.m.
Trial Oct. 29, 2018 No change None
8:30 a.m.
The parties submit that good cause exists for the following reasons.
1. The Scheduling Order was initially issued on June 21, 2017, and modified pursuant to the parties' joint request on February 14, 2018 and March 12, 2018. The currently requested extension is for the fact discovery cut-off only and does not delay the dates for filing dispositive motions, or for the pretrial conference and trial.
2. The parties are actively engaged in settlement negotiations and have reached a tentative agreement on the amount of the settlement, but are continuing to negotiate the scope of the release and whether the settlement of this action should satisfy the judgment against a non-party in a previous case, and wish to attempt a resolution of this matter before incurring further expense of discovery.
3. The parties have propounded written discovery and have conferred regarding the setting of depositions. The parties have agreed on the following discovery plan, subject to the Court's granting their joint request to modify the schedule:
• April 27, 2018 — Defendant's Responses to Plaintiffs' Written Discovery due.
• May 9, 2018 — Plaintiff's Responses to Defendants' Written Discovery due.
• Depositions may be conducted at any time pursuant to the Federal Rules of Civil Procedure and the Civil Local Rules, or by mutual agreement.
7. The parties respectfully request that the Court approve this stipulation and incorporate its terms in an Order.
IT IS SO STIPULATED.
No further continuances will be granted based on the parties' efforts to reach a settlement.
IT IS SO ORDERED.
