Filed: Mar. 29, 2018
Latest Update: Mar. 29, 2018
Summary: AMENDED STIPULATED REQUEST TO REVISE CASE MANAGEMENT DATES AND CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER LAUREL BEELER , Magistrate Judge . Pursuant to stipulation of the parties and Court Order dated February 2, 2018, Dkt. No. 34, the parties submit this Stipulated Request to Revise Case Management Dates and to Continue the Case Management Conference. 1. The parties have met and conferred regarding the need for a further case management conference and have agreed that
Summary: AMENDED STIPULATED REQUEST TO REVISE CASE MANAGEMENT DATES AND CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER LAUREL BEELER , Magistrate Judge . Pursuant to stipulation of the parties and Court Order dated February 2, 2018, Dkt. No. 34, the parties submit this Stipulated Request to Revise Case Management Dates and to Continue the Case Management Conference. 1. The parties have met and conferred regarding the need for a further case management conference and have agreed that,..
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AMENDED STIPULATED REQUEST TO REVISE CASE MANAGEMENT DATES AND CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER
LAUREL BEELER, Magistrate Judge.
Pursuant to stipulation of the parties and Court Order dated February 2, 2018, Dkt. No. 34, the parties submit this Stipulated Request to Revise Case Management Dates and to Continue the Case Management Conference.
1. The parties have met and conferred regarding the need for a further case management conference and have agreed that, apart from an adjustment to the several of the case management dates, there is no need for a further case management conference at this time.
2. The parties agree that a bifurcation of liability and damages discovery remains in the best interest of case management efficiency, but the convenience of the plaintiff and third party deponents dictates that some of the damages discovery be completed concurrently with liability discovery.
Accordingly, the parties agree that a modification to the case management schedule is appropriate.
3. Subject to the Court's approval, the parties have agreed upon the following modifications to the case management schedule and jointly request that the Court modify the schedule accordingly:
Case Event Current Date Proposed Date
Non-expert discovery April 20, 2018 November 26, 2018 (same as
completion date (liability) non-expert damages discovery)
Expert disclosures (liability) May 4, 2018 June 15, 2018
Rebuttal expert disclosures May 18, 2018 June 29, 2018
(liability)
Expert discovery completion June 8, 2018 July 13, 2018
(liability)
Last hearing date for dispositive August 16, 2018 at 9:30 a.m. / September 13, 2018
motions (liability) / Further CMC 11:00 a.m.
The remaining dates in the Case Management Order, Dkt. No. 29, remain the same.
4. The parties further agree that, subject to the Court's approval of the above case management date modifications, the Case Management Conference scheduled for April 5, 2018, is not necessary at this time, and the parties request that the Court continue the conference to such later date as the Court deems appropriate.
CERTIFICATION
Pursuant to Civil Local Rule 5-1(i)(3), the filer of this document attests under penalty of perjury that counsel for Plaintiff has concurred in the filing of this document.
[PROPOSED] CASE MANAGEMENT ORDER
Pursuant to stipulation of the parties and good cause appearing therefor, it is hereby ordered that the Case Management Order dated October 12, 2017, Dkt. No. 29, is revised as follows:
Case Event Filing Deadline/Disclosure
Deadline/Hearing Date
Non-expert discovery completion date November 26, 2018
Expert disclosures (liability) June 15, 2018
Rebuttal expert disclosures (liability) June 29, 2018
Expert discovery completion (liability) July 13, 2018
Last hearing date for dispositive motions (liability) / September 13, 2018 at 9:30 a.m./11:00 a.m.
Further Case Management Conference
It is further ordered that the Case Management Conference scheduled for April 5, 2018, is continued until June 7, 2018. The parties must notice the motion for 9/13/2018 at 9:30 a.m.
