STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR EXPERT DISCLOSURES

JOSEPH C. SPERO, District Judge.

STIPULATION

WHEREAS, the court, following recommendation by the parties, scheduled these important dates by way of its July 8, 2013 Case Management and Pre-Trial Order (Jury): (1) deadline for initial expert disclosure on March 14, 2014; and (2) completion of non-expert discovery by May 23, 2014; and

WHEREAS, the parties, who have been working diligently on the preparation of their respective cases, are still in the process of conducting and have not yet completed essential discovery, including without limitation document production, depositions, and inspections of defendants' land and equipment; and

WHEREAS, the foregoing discovery, which will continue through and after March 14, 2014, may lead to the need for additional discovery; and

WHEREAS, the parties, who believe it is necessary and proper to conduct and complete all outstanding discovery prior to disclosing experts in accordance with the Federal Rules of Civil Procedure, hereby submit that good cause exists for an extension of the current expert disclosure date from March 14, 2014 to May 23, 2014, so as to coincide with the current completion date for non-expert discovery; and

WHEREAS, the parties' requested extension of the deadline for initial expert disclosure will not affect other important dates, including the trial and pre-trial conference dates, completion of expert and non-expert discovery dates, and the dispositive motion hearing date.

NOW, THEREFORE, AND IN CONSIDERATION OF THE FOREGOING, the parties, through their respective counsel, hereby stipulate as follows:

1. The deadline to serve initial expert witness disclosures and expert reports in compliance with the Federal Rules of Civil Procedure shall be extended from March 14, 2014 to May 23, 2014.

2. The deadline to serve all rebuttal expert witness disclosures and expert reports in compliance with the Federal Rules of Civil Procedure shall be extended from April 11, 2014, to June 20, 2014.

3. No other dates currently on calendar, including the trial and pre-trial conference dates, completion of expert and non-expert discovery dates, and the dispositive motion hearing date shall be affected by this stipulation.

4. This stipulation may be executed in counterparts.

ORDER

WHEREAS, good cause exists for the relief requested herein, the court hereby makes the foregoing stipulation the order of the court.

IT IS SO ORDERED.