Filed: May 12, 2014
Latest Update: May 12, 2014
Summary: STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES; AND NOTICE OF WITHDRAWAL OF MOTION MAXINE M. CHESNEY, District Judge. AML Group Limited ("AML"), McCrane, Inc. d/b/a Harbinger ("Harbinger") and David P. McCrane (collectively with Harbinger, "McCrane"), by and through their counsel of record, hereby stipulate as follows: 1. On January 27, 2014, the Court entered an Amended Pretrial Order, which set various case management deadlines, including expert discovery cutoff dates of April 4
Summary: STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES; AND NOTICE OF WITHDRAWAL OF MOTION MAXINE M. CHESNEY, District Judge. AML Group Limited ("AML"), McCrane, Inc. d/b/a Harbinger ("Harbinger") and David P. McCrane (collectively with Harbinger, "McCrane"), by and through their counsel of record, hereby stipulate as follows: 1. On January 27, 2014, the Court entered an Amended Pretrial Order, which set various case management deadlines, including expert discovery cutoff dates of April 4,..
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STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES; AND NOTICE OF WITHDRAWAL OF MOTION
MAXINE M. CHESNEY, District Judge.
AML Group Limited ("AML"), McCrane, Inc. d/b/a Harbinger ("Harbinger") and David P. McCrane (collectively with Harbinger, "McCrane"), by and through their counsel of record, hereby stipulate as follows:
1. On January 27, 2014, the Court entered an Amended Pretrial Order, which set various case management deadlines, including expert discovery cutoff dates of April 4, 2014 for the designation of experts, April 18 for rebuttal experts, and May 9, 2014 for the close of expert discovery.
2. On March 26, 2014, the parties convened before the Hon. Rebecca Westerfield (Ret.) of JAMS to mediate this dispute. With Judge Westerfield's assistance, the parties diligently engaged in more than a full day of settlement discussions. Although the parties were not able to resolve the matter in that session, Judge Westerfield opined that the parties had made substantial progress toward a negotiated resolution and that continued, unimpeded settlement discussions would be productive and should remain the parties' top priority. The parties and Judge Westerfield agreed that a brief extension on the fast-approaching expert cutoff deadlines would help to facilitate a resolution by allowing the parties to focus on their ongoing negotiations without the distraction and expense of potentially unnecessary litigation. The parties thus filed two stipulated requests for extension of discovery cutoff deadlines, which this Court granted on March 28, 2014 [Dkt. Nos. 44-45] and April 21, 2014 [Dkt. No. 47], respectively.
3. Since that time, the parties have continued to engage in fruitful settlement negotiations, which have been somewhat complicated by significant time zone differences and counsel for McCrane's involvement in a two-week jury trial in late April.
4. In light of the parties' ongoing settlement discussions, the parties hereby stipulate to, and respectfully request the following relief:
a. The deadline for initial expert witness disclosures, currently May 2, 2014, shall be extended to May 16, 2014;
b. The deadline for rebuttal expert disclosures, currently May 16, 2014, shall be extended to May 30, 2014;
c. The expert discovery cutoff, currently May 23, 2014, shall be extended to June 20, 2014;
d. McCrane shall withdraw its Motion for an Order Extending Expert Disclosure [Dkt. No. 48] as moot;
5. Except as expressly stated herein, all provisions of the Amended Pretrial Order shall remain the same.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
