STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME TO FILE STIPULATED DISCOVERY PLAN AND PROPOSED SCHEDULING ORDER

[FIRST REQUEST FOR EXTENSION]

CARL W. HOFFMAN, Magistrate Judge.

Pursuant to this Court's order and consistent with the Federal Rules of Civil Procedure, rule 26 and Local Rule 26-1, the parties' stipulated discovery plan and proposed scheduling order is to be filed by December 26, 2017. Plaintiff MARK HUNT ("Hunt"), and Defendants ZUFFA, LLC d/b/a ULTIMATE FIGHTING CHAMPIONSHIP ("Zuffa"), DANA WHITE ("White") and BROCK LESNAR ("Lesnar") hereby stipulate to extend the deadline for parties to file the stipulated discovery plan and proposed scheduling order for ten (10) days, until January 5, 2018. This stipulation is based on the following:

Defendants Lesnar, Zuffa, and White have pending motions to dismiss before the Court. Hunt filed a motion for leave to file a supplemental complaint on December 15, 2017. (ECF No. 100.) Counsel for all parties have conferred via e-mail regarding the stipulated discovery plan and proposed scheduling order. This action will involve a high volume of documents and electronic information. Counsel for Zuffa has advised it will seek a stipulated protective order; Hunt and Lesnar will negotiate in good faith to reach mutually agreeable stipulated protective order. The Court's order on Lesnar's motion to stay discovery, consistent with Hunt's agreement to stay RICO-related discovery, ordered that discovery will be stayed as to Hunt's first and second claims, but shall otherwise proceed on all other claims.

Counsel for all parties intend to meet telephonically to discuss a discovery plan, scheduling, and case-specific issues regarding a stipulated protective order and consideration of crafting a discovery plan subject to the partial discovery stay. The parties request a brief extension to permit lead counsel for all parties to participate in the telephonic conference of counsel, and submit this will facilitate reaching potential discovery agreements and stipulations consistent with F.R.C.P. 26 and LR 26-1. The parties have been unable to coordinate a mutually convenient time for lead counsel to participate in the telephonic conference prior to the Christmas holiday due to calendaring conflicts with other matters and pre-existing travel obligations. The stipulated discovery plan and proposed scheduling order is currently due on December 26, 2017. This is the first request for an extension of time.

Based on the foregoing, good cause exists and the parties hereby stipulate and request that the Court issue an Order extending the deadline to file the stipulated discovery plan and proposed scheduling order ten (10) days to January 5, 2018.

IT IS SO ORDERED.