Filed: Jun. 19, 2019
Latest Update: Jun. 19, 2019
Summary: STIPULATION AND ORDER TO EXTEND AND SET DEADLINES MORRISON C. ENGLAND, JR. , District Judge . Defendant Merz North America, Inc. ("Defendant") and Plaintiffs Marilyn Echols and Georgia Tryan ("Plaintiffs"), collectively, the "Parties," by and through their counsel of record, submit this Stipulation and [Proposed] Order to Extend and Set Deadlines. 1. WHEREAS, since Merz filed its Answer to the Complaint on September 27, 2018, the Parties have been diligently conducting fact discovery and d
Summary: STIPULATION AND ORDER TO EXTEND AND SET DEADLINES MORRISON C. ENGLAND, JR. , District Judge . Defendant Merz North America, Inc. ("Defendant") and Plaintiffs Marilyn Echols and Georgia Tryan ("Plaintiffs"), collectively, the "Parties," by and through their counsel of record, submit this Stipulation and [Proposed] Order to Extend and Set Deadlines. 1. WHEREAS, since Merz filed its Answer to the Complaint on September 27, 2018, the Parties have been diligently conducting fact discovery and di..
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STIPULATION AND ORDER TO EXTEND AND SET DEADLINES
MORRISON C. ENGLAND, JR., District Judge.
Defendant Merz North America, Inc. ("Defendant") and Plaintiffs Marilyn Echols and Georgia Tryan ("Plaintiffs"), collectively, the "Parties," by and through their counsel of record, submit this Stipulation and [Proposed] Order to Extend and Set Deadlines.
1. WHEREAS, since Merz filed its Answer to the Complaint on September 27, 2018, the Parties have been diligently conducting fact discovery and discussing the prospect of an early resolution to this matter.
2. WHEREAS, on or around June 12, 2019, the Parties agreed that early resolution to this matter is unlikely at this juncture of the case and additional time is needed to complete discovery.
3. WHEREAS, the Parties also agreed that deadlines should be set for a motion for summary judgment, motion for class certification, and expert discovery.
4. WHEREAS, good cause exists to extend the discovery deadline because of the volume of documents involved in the Parties' e-discovery, and the need for additional time to complete the depositions of Georgia Tryan, Merz, and potentially other deponents.
5. WHEREAS, good cause exists to enter the deadlines proposed below because they correspond with the Parties' anticipated completion of discovery, and the time needed to brief substantive motions.
THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE that the deadline to complete fact discovery should be extended, and the following deadlines should be entered in this case:
Fact Discovery Cut-Off October 4, 2019
Motion for Summary Judgment Due for Filing October 18, 2019
Opposition to Motion for Summary Judgment Due November 27, 2019
for Filing
Reply to Motion for Summary Judgment Due for December 11, 2019
Filing
Hearing on Motion for Summary Judgment December 19, 2019 at 2:00 p.m.
in Courtroom 7
Motion for Class Certification Due for Filing February 4, 2020
Deadline for Plaintiffs to Disclose Class and Merits February 4, 2020
Expert(s) and Report(s)
Deposition(s) of Plaintiffs' Expert(s) February 24 to March 6, 2020
Opposition to Class Certification Due for Filing April 3, 2020
Deadline for Merz to Disclose Class and Merits April 3, 2020
Expert(s) and Report(s)
Deposition(s) of Merz's Expert(s) April 27 to May 8, 2020
Reply for Motion for Class Certification Due for May 22, 2020
Filing
Hearing on Motion for Class Certification June 11, 2020 at 2:00 p.m.
in Courtroom 7
DATED: June 17, 2019 CAPSTONE LAW APC
By: /s/ Trisha K. Monesi
Trisha K. Monesi
Attorneys for Plaintiffs
GEORGIA TRYAN and MARILYN ECHOLS
Dated: June 17, 2019. McGUIREWOODS LLP
By: /s/ Bethany G. Lukitsch
Bethany G. Lukitsch
Molly M. White
Arsen Kourinian
Jim Neale
Attorneys for Defendant
MERZ NORTH AMERICA, INC.,
IT IS SO ORDERED.
