Filed: Jan. 12, 2018
Latest Update: Jan. 12, 2018
Summary: FIRST JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE FACT DISCOVERY TROY L. NUNLEY , District Judge . Pursuant to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule 144(d), Plaintiff Antonio A. Lopez ("Plaintiff") and Defendant Pre-employ.com, Inc. ("Pre-employ") (collectively, the "Parties"), by and through their respective counsel of record, hereby agree and stipulate to as follows: 1. On September 15, 2016, Plaintiff filed his Complaint. 2. On September 16, 2016, this Co
Summary: FIRST JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE FACT DISCOVERY TROY L. NUNLEY , District Judge . Pursuant to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule 144(d), Plaintiff Antonio A. Lopez ("Plaintiff") and Defendant Pre-employ.com, Inc. ("Pre-employ") (collectively, the "Parties"), by and through their respective counsel of record, hereby agree and stipulate to as follows: 1. On September 15, 2016, Plaintiff filed his Complaint. 2. On September 16, 2016, this Cou..
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FIRST JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE FACT DISCOVERY
TROY L. NUNLEY, District Judge.
Pursuant to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule 144(d), Plaintiff Antonio A. Lopez ("Plaintiff") and Defendant Pre-employ.com, Inc. ("Pre-employ") (collectively, the "Parties"), by and through their respective counsel of record, hereby agree and stipulate to as follows:
1. On September 15, 2016, Plaintiff filed his Complaint.
2. On September 16, 2016, this Court issued Summons for Pre-employ and directed Pre-employ to respond to Plaintiff's Complaint within 21 days after service of the Summons.
3. On October 14, 2016, Plaintiff served the Summons and Complaint on Pre-employ.
4. On October 26, 2016, pursuant to Local Rule 144(a), Plaintiff and Defendant stipulated to Defendant's first request for a 28-day extension to respond to Plaintiff's Complaint.
5. On December 2, 2016, Pre-employ filed its Answer to Plaintiff's Complaint.
6. On January 19, 2017, this Court issued its Pretrial Scheduling Order. ECF No. 10. The Pretrial Order set the following deadlines:
a. Deadline to conduct and complete fact discovery: February 1, 2018;
b. Deadline to disclose expert witnesses: April 5, 2018;
c. Deadline to hear dispositive motions by: August 9, 2018;
d. Final Pretrial Conference date: November 1, 2018;
e. Joint Final Pretrial Conference date: October 25, 2018;
f. Trialdate: January 7, 2019.
7. According to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule 144(d), the Parties request this Court to extend the deadline to complete fact discovery to March 1, 2018.
8. Good cause exists to grant this request because the Parties have been diligent in conducting discovery and have been cooperative throughout the discovery period. To date, the Parties have served and responded to written discovery, and Pre-employ has subpoenaed the production of documents from three non-parties. In addition, on December 6, 2017, Pre-employ issued subpoenas for deposition testimony from two non-parties, but is still coordinating dates to depose the non-party witnesses. The Parties are also coordinating dates to take Plaintiff's and Pre-employ's depositions at this time, and do not expect to finish taking all depositions prior to February 1, 2017. Finally, extending the deadline to complete fact discovery will not require the Court to extend any additional discovery or scheduling deadlines.
9. Accordingly, the Parties stipulate to the Court extending the discovery deadline to complete fact discovery to March 1, 2018.
IT IS SO STIPULATED.
IT IS SO ORDERED.
