STIPULATION TO EXTEND DISCOVERY

CARLA BALDWIN CARRY, Magistrate Judge.

Plaintiff GUISELA AGUIRRE GUERRA ("Plaintiff"), and Defendant DEMATIC CORP., a Delaware corporation ("Defendant"), pursuant to LR II 7-1, hereby stipulate and agree as follows:

Whereas, the parties have completed the following discovery in the above-captioned matter: (1) The parties filed their Joint Case Management Report on August 22, 2018; (2) Plaintiff made its Fed.R.Civ.P. 26 Disclosures on August 29, 2018, and First and Second Supplements thereto on December 7, 2018 and January 8, 2019; (3) Defendant made its Fed.R.Civ.P. 26 Disclosures on November 15, 2018; (4) Plaintiff served Defendant with its first set of interrogatories and requests for production of documents on September 4, 2018 and Defendant responded to same on October 31, 2018; (5) Plaintiff served Sally Beauty Supply, LLC with two Subpoenas Duces Tecum one on September 11, 2018 and another on October 11, 2018; (6) Defendant served Plaintiff with its first set of requests for admissions, interrogatories and requests for production of documents on December 13, 2018 and Plaintiff responded to same on January 14, 2019; (7) Plaintiff served Defendant with its first set of requests for admissions and second set of requests for production of documents on January 8, 2019; and (8) Plaintiff served Sally Beauty Supply, LLC with a Subpoena for Inspection, Testing and Photography on December 11, 2018 and the parties conducted an inspection of the subject "Gate" on January 14, 2019.

Plaintiff has substituted in, for Black Corporation A, SIEMENS INDUSTRY, INC.

Defendant recently filed a Third-Party Complaint against SALLY BEAUTY SUPPLY, LLC F/K/A SALLY BEAUTY COMPANY, INC. ("Sally Beauty Supply"), with allegations, inter alia, that Sally Beauty Supply entered into a contractual indemnity agreement with Defendant or its predecessor that has been triggered by the claims raised in the Complaint. Sally Beauty Supply has been served, but its Answer is not due at this time.

Given the date (approximately 1999) of the design, manufacture, sale and installation of the Gate (as that term is defined in Plaintiff's First Amended Complaint) and subsequent corporate mergers, Plaintiff and Defendant are currently working on a stipulation to clarify which parties are legally responsible for any liability arising out of the design, manufacture, sale and installation of the Gate.

Given the addition of Sally Beauty Supply as a Third-Party Defendant, Plaintiff and Defendant anticipate the need for additional discovery, particularly so that adequate time exists to depose Plaintiff's treating physicians prior to all sides' experts being deposed and therefore stipulate to extend all discovery, motion and pretrial order deadlines set forth in the Court's Minute Order of August 29, 2018.

Plaintiff and Defendant anticipate convening a new joint case conference and preparing and filing a new Joint Case Management Report promptly upon the appearance of Sally Beauty Supply.

This is the first stipulation to extend the time for discovery and to file motions, and this stipulation is not made for any improper purpose.

NOW, THEREFORE, and good cause appearing, it is hereby stipulated and agreed as follows:

1. That the deadlines set forth in the Court's Minute Order of August 29, 2018 be set aside, and that new deadlines be established at the time of a new Case Management Conference which shall be scheduled upon the appearance of Sally Beauty Supply.

IT IS SO ORDERED.