JOINT STIPULATION TO CONTINUE NON-EXPERT DISCOVERY CUT-OFF; ORDER

MORRISON C. ENGLAND, Jr., Magistrate Judge.

TO THE HONORABLE COURT:

Plaintiff and Defendant hereby join in requesting that the Court adjust the pretrial discovery completion date of March 13, 2017 in order to allow the parties to complete necessary discovery. This request does not seek a change of the other pretrial dates.

This request is based upon the following stipulation and statement of counsel:

1. Pursuant to the Court's Amended Pretrial Scheduling Order [Dkt. # 16], all discovery, excluding expert discovery, is to be completed by March 13, 2017.

2. Counsel for Plaintiff and Defendant have been working together to timely complete discovery. Indeed, aside from initial disclosures, the parties have exchanged additional written discovery and responsive documents, which was necessary before scheduling depositions. In scheduling depositions of the parties' respective current and former employees, however, the parties and their counsel encountered unexpected scheduling conflicts.

3. At this time, the parties have agreed to the following deposition schedule:

4. The parties are also still working to coordinate the depositions of Plaintiff's other former employees, Craig Emerson and Lars Miller, who have been unresponsive to communications from counsel for both parties.

5. Further, it is anticipated that once the above-noted depositions are completed, the parties may need to conduct additional depositions and written discovery based upon the testimony of the deponents.

6. As the parties have been cooperating to complete non-expert discovery as efficiently as possible, have agreed to complete the outstanding depositions and potential additional discovery as soon as reasonably possible, and that the other pretrial deadlines will not be affected, the parties believe extending the non-expert discovery completion deadline as requested will not needlessly delay the matter (which has not been set for trial) and rather will facilitate potential resolution of the entire case. Accordingly, good cause exists to continue the non-expert discovery deadline and the parties jointly request that the Court further amend the

ORDER

Upon reviewing the parties' Joint Stipulation to Continue the Non-Expert Discovery Cut-Off, and the Court finding good cause to modify its September 7, 2016 Amended Pretrial Scheduling Order (ECF No. 16), the Court Orders that the current non-expert discovery completion date of March 13, 2017, is hereby continued to June 2, 2017.

IT IS SO ORDERED.