STIPULATION TO REQUEST MODIFICATION OF SCHEDULING ORDER FOR GOOD CAUSE

WILLIAM B. SHUBB, District Judge.

TO THE COURT AND ALL INTERESTED PARTIES AND THEIR ATTORNEYS OF RECORD:

WHEREAS, this putative collective action was filed on June 10, 2016, asserting that Defendant violated the overtime payment provisions of the Fair Labor Standards Act ("FLSA");

WHEREAS, the Court issued an order conditionally certifying this case as a collective action on November 10, 2016 and facilitating notice;

WHEREAS, the Court set in its Initial Pretrial Scheduling Order the following deadlines:

Last Day to Disclose Expert Witnesses and Reports: September 1, 2017

Last Day to Disclose Rebuttal Expert Witnesses and Reports: November 1, 2017

Last Day to Complete all Discovery: January 17, 2018

Last Day to File Dispositive or Evidentiary Motions: February 12, 2018

Final Pre-Trial Conference: April 23, 2018, at 1:30 p.m. in Courtroom No. 5.

Settlement Conference: To be set at the Final Pre-Trial Conference

Trial: July 24, 2018 at 9:00 a.m. (10 days in length)

WHEREAS, since the Court granted conditional certification multiple additional plaintiffs have opted into this action;

WHEREAS, Plaintiffs have diligently propounded multiple types of written discovery which the Defendant needs additional time to respond to;

WHEREAS, the parties have continued to act diligently in scheduling and conducting discovery, and in discussing potential resolutions to this action up and through the date of this stipulation;

WHEREAS, additional time will allow the parties to complete written discovery and attempt to resolve the action through direct settlement communications or alternative dispute resolution;

IT IS HEREBY STIPULATED by the Parties and requested that:

1. Based on good cause shown to allow for early informal resolution, as discussed above, the parties propose the following modification of deadlines in the Court's Initial Scheduling Order:

Last Day to Disclose Expert Witnesses and Reports: December 1, 2017

Last Day to Disclose Rebuttal Expert Witnesses and Reports: January 2, 2018

Last Day to Complete all Discovery: April 17, 2018

Last Day to File Dispositive or Evidentiary Motions: May 12, 2018

Final Pre-Trial Conference: July 23, 2018, at 1:30 p.m. in Courtroom No. 5.

Settlement Conference: To be set at the Final Pre-Trial Conference

Trial: October 24, 2018 at 9:00 a.m. (10 days in length)

ORDER

GOOD CAUSE SHOWN, IT IS SO ORDERED that the following dates currently set forth in its Initial Scheduling Order are amended to the following:

Last Day to Disclose Expert Witnesses and Reports: December 1, 2017

Last Day to Disclose Rebuttal Expert Witnesses and Reports: January 2, 2018

Last Day to Complete all Discovery: April 17, 2018

Last Day to File Dispositive or Evidentiary Motions: May 12, 2018

Final Pre-Trial Conference: August 27, 2018, at 1:30 p.m. in Courtroom No. 5.

Settlement Conference: To be set at the Final Pre-Trial Conference

Trial: October 30, 2018 at 9:00 a.m. (10 days in length)