STIPULATED MOTION AND ORDER RE: DEPOSITION SCHEDULING

NOTE ON MOTION CALENDER September 20, 2019

JAMES L. ROBART, District Judge.

WHEREAS the fact discovery deadline in this case is September 30, 2019 (Dkt. 17);

WHEREAS counsel for the parties are working together to complete depositions of party and third-party witnesses resident in various locations throughout the United States and abroad;

WHEREAS many of the deponents in this case have sales roles that require significant travel and create logistical difficulties in scheduling depositions;

WHEREAS to minimize disruption to the parties' and deponents' respective business operations and to attempt to reduce travel costs and inconvenience to party and third-party witnesses, the parties seek leave to conduct depositions during the first two weeks in October 2019 where needed to accommodate witness schedules;

WHEREAS the parties have not sought any other modifications to the Court's scheduling order, and permitting depositions to occur through October 11, 2019 will not impact the trial schedule or any other case management deadlines;

WHEREAS the parties respectfully submit that there is good cause to permit depositions to occur through October 11, 2019 in order to reduce overall litigation costs, achieve the prompt completion the case, to minimize the costs of discovery, and to allow counsel to creatively and cooperatively manage deposition scheduling on a cost-effective basis (see Introduction to W.D. Wash. Local Civil Rules),

NOW THEREFORE, the parties respectfully authorization to allow depositions to occur in this matter until October 11, 2019.

I hereby attest that the concurrence in the filing of this document has been obtained from each of the other signatories hereto.

Good cause having been shown, IT IS HEREBY ORDERED that the parties may take depositions through October 11, 2019.