Filed: Feb. 14, 2018
Latest Update: Feb. 14, 2018
Summary: STIPULATION AND JOINT REQUEST TO MODIFY SCHEDULING ORDER TO EXTEND DISCOVERY CUT-OFF DATES; 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, issued June 21, 2017 (Doc. No. 26), as follows: Event Scheduled Date Requested Date Previous Extension Fact discovery cut-off
Summary: STIPULATION AND JOINT REQUEST TO MODIFY SCHEDULING ORDER TO EXTEND DISCOVERY CUT-OFF DATES; 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, issued June 21, 2017 (Doc. No. 26), as follows: Event Scheduled Date Requested Date Previous Extension Fact discovery cut-off ..
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STIPULATION AND JOINT REQUEST TO MODIFY SCHEDULING ORDER TO EXTEND DISCOVERY CUT-OFF DATES; 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, issued June 21, 2017 (Doc. No. 26), as follows:
Event Scheduled Date Requested Date Previous Extension
Fact discovery cut-off Feb. 28, 2018 Mar. 30, 2018 None
Expert disclosures Mar. 22, 2018 Apr. 23, 2018 None
Expert rebuttal Apr. 22, 2018 May 15, 2018 None
Expert discovery cutoff May 25, 2018 June 1, 2018 None
Deadline to file dispositive Jun. 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 above schedule was set by the Court in its Scheduling Order on June 21, 2017. The parties have not requested any previous extensions of these dates. The requested extensions are for discovery cut-off dates only and do not delay the dates for filing dispositive motions, or for the pretrial conference and trial.
2. The parties are engaged in settlement negotiations 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. A number of deponents are not available in February but are available in March. The parties have agreed on the following discovery plan, subject to the Court's granting their joint request to modify the schedule:
March 5, 2018 — Plaintiffs' Responses to Defendant's Written Discovery due
March 14, 2018 — Depositions of Trustees James Beno and Doug Cornford
March 19, 2018 — Defendant's Responses to Plaintiffs' Written Discovery due
March 16, 19, or 20 — Deposition of Trust Fund 30(b)(6)
March 1 — 30 — Third-Party Depositions
March 21 — 30 — Depositions of Defendants William Brunelli, James Brunelli, Brennan
Rose, Mike Rose's Auto Body, Inc. 30(b)(6), and Washington Township Central Investment 30(b)(6).
7. The parties respectfully request that the Court approve this stipulation and incorporate its terms in an Order.
IT IS SO STIPULATED.
