PROPOSED SCHEDULING ORDER

HAYWOOD S. GILLIAM, District Judge.

On June 9, 2015, the Parties' counsel appeared before the Court for a Fed. R. Civ. P. 16 Case Management Conference. At the Case Management Conference, the Court indicated that all fact discovery in this case should be completed by no later than January 15, 2016, motions to amend the complaint should be filed by June 23, 2015, and the first day of trial should be set two months or ten weeks from the dispositive motion hearing date. (Docket No. 25) The Court ordered the Parties' counsel to meet and confer further concerning all other case management deadlines.

The parties have met and conferred regarding the relevant dates and sought to structure a timeline permitting the parties to consider mediation after the court's ruling on dispositive motions and before work on trial preparation begins in earnest.

Defendant's Position:

If the last day to hearing dispositive motions is March 31, 2016, a 60-day window between the ruling and the beginning of trial preparation would be approximately June 15. Allowing 30 days for trial preparation would yield a trial date of approximately July 15. However, lead trial counsel for Plaintiffs is out of the country from the beginning of July to mid-August. Thus, the trial date must be moved to early June or early September. Defendant's position is that moving it to early June would make it difficult for the parties to hold a mediation after obtaining a ruling on dispositive motions and before beginning trial preparation. Defendant's position is that moving it to early September would impose a modest delay but would have no other consequence.

Plaintiffs' Position:

If the last day to hear dispositive motions is March 31, 2016, a 60-day window between the hearing and the first day of trial would be approximately May 30, 2016. A ten-week window would set the first day of trial for approximately June 9, 2016.

Plaintiffs do not object to a September trial date. However, if the Court is inclined to set the trial date within sixty days or ten weeks of the dispositive motion hearing date, Plaintiffs request that the trial be set for no later than June 13, 2016, given that Plaintiffs' lead trial counsel will be out of the country for most of July and August.

Accordingly, after having had met and conferred with each other, the Parties and their counsel hereby suggest that the Court set the following case management deadlines: