JOINT STIPULATION TO CONTINUE NON-TRIAL DISCOVERY RELATED DATES AND [PROPOSED] ORDER THEREON

MICHAEL J. SENG, Magistrate Judge.

Plaintiff Charles Johnson ("Plaintiff"), on the one hand, and Defendants Republic Services, Inc. and Allied Waste Services of North America, LLC ("Defendants") on the other, by and through their respective counsel of record, hereby stipulate and agree as follows:

WHEREAS, on March 31, 2016, a Scheduling Conference was held and dates were set including a discovery cut off, expert disclosure deadlines, non-dispositive and dispositive motion deadlines, a Final Pretrial Conference on April 10, 2017, and a five day Jury Trial on May 31, 2017;

WHEREAS, the Parties have been diligently engaging in written discovery and plan on taking the depositions of Plaintiff and additional Company witnesses of Defendants in October of 2016;

WHEREAS, the Parties would like a short continuance of approximately six (6) weeks on all discovery-related deadlines in order to allow them to adequately complete discovery;

WHEREAS, the requested short continuance will not impact the hearing date on any dispositive motions, the Final Pretrial Conference or Jury Trial date;

WHEREAS, counsel for the Parties are working collaboratively to move the case along efficiently;

WHEREAS, no prior continuances have been granted in this matter and no party will suffer prejudice as a result of the proposed short continuance;

NOW, THEREFORE, Plaintiff and Defendants, by and through their attorneys of record, hereby stipulate that the below dates be continued as follows:

IT IS SO STIPULATED.

ORDER

Counsel for the Parties in the above-captioned action submitted a Joint Stipulation to Continue all Non-Trial Discovery Related Deadlines.

After consideration of the papers submitted, and good cause appearing therefore, it is hereby ORDERED that, the below deadlines be continued as follows:

IT IS SO ORDERED.