STIPULATION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER

GARLAND E. BURRELL, Jr., Senior District Judge.

Whereas, the parties originally agreed to limit each party to ten depositions of fact witnesses, and the Court adopted that agreement in its pre-trial scheduling order;

Whereas, the parties originally agreed to disclose expert witnesses by April 7, 2014, and the Court adopted that agreement in its pre-trial scheduling order;

Whereas, the parties have been unable to complete enough discovery to sufficiently prepare their respective experts due to circumstances outside of their control;

Whereas, additional witnesses have been identified through the course of discovery;

Whereas, the inability to prepare experts and the identification of new witnesses presents good cause to amend the pre-trial scheduling order;

Whereas, no party will be prejudice by the proposed amendments, The parties stipulate as follows:

1. With the consent of the Court, The Pre-Scheduling Order will be amended to such that each party shall comply with Federal Rule of Civil Procedure 26(a)(2)(B) and (C)'s initial expert disclosure requirements on or before May 22, 2014, and any contradictory and/or rebuttal expert disclosure authorized under Rule 26(a)(2)(D)(ii) on or before June 22, 2014;

2. With the consent of the Court, the parties agree to allow two (2) additional fact witness depositions per side, such that each party will now be permitted twelve (12) total fact witness depositions.

IT IS SO ORDERED: