Filed: Apr. 25, 2018
Latest Update: Apr. 25, 2018
Summary: JOINT GOOD CAUSE STATEMENT, REQUEST AND ORDER TO EXTEND CASE DEADLINES HAYWOOD S. GILLIAM, JR. , District Judge . The undersigned parties to this action, by and through their undersigned counsel, hereby request that the Court amend the case schedule as follows and provide the following particularized reasons showing good cause for the requested changes pursuant to the Court's Standing Order for Civil Cases: On August 4, 2017, the parties stipulated to and the Court ordered a case schedule.
Summary: JOINT GOOD CAUSE STATEMENT, REQUEST AND ORDER TO EXTEND CASE DEADLINES HAYWOOD S. GILLIAM, JR. , District Judge . The undersigned parties to this action, by and through their undersigned counsel, hereby request that the Court amend the case schedule as follows and provide the following particularized reasons showing good cause for the requested changes pursuant to the Court's Standing Order for Civil Cases: On August 4, 2017, the parties stipulated to and the Court ordered a case schedule. ..
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JOINT GOOD CAUSE STATEMENT, REQUEST AND ORDER TO EXTEND CASE DEADLINES
HAYWOOD S. GILLIAM, JR., District Judge.
The undersigned parties to this action, by and through their undersigned counsel, hereby request that the Court amend the case schedule as follows and provide the following particularized reasons showing good cause for the requested changes pursuant to the Court's Standing Order for Civil Cases:
On August 4, 2017, the parties stipulated to and the Court ordered a case schedule. Dkt. 64. On January 16, 2018, Plaintiffs filed a motion for leave to file a Fourth Amended Complaint that adds seven new causes of action and two individual defendants, Dkt. 82, which the Court granted on April 13, 2018, Dkt. 91. The new claims in the Fourth Amended Complaint include breach of contract, fraudulent concealment, conversion, libel, intentional interference with contractual relations, breach of fiduciary duty, and breach of the implied covenant of good faith and fair dealing. See Dkt. 92-4. In response to the Court's guidance at the hearing on Plaintiffs' motion for leave to file a Fourth Amended Complaint, the parties met and conferred regarding the current case schedule.
In light of the order granting Plaintiffs' leave to file the Fourth Amended Complaint, the parties agree that additional discovery is necessary and hereby request to extend the trial date and related case deadlines approximately 90 days given the expanded scope of the case. Further, the parties agree that Defendants will not bring a motion to dismiss, but instead will combine their motion to dismiss with their summary judgment motion. Moreover, the parties agree that Defendants can each serve one set of written discovery requests (requests for production, interrogatories and requests for admission). The parties will then meet and confer to discuss whether further discovery is necessary for either party. The parties agree discovery will be limited to Defendants' written discovery mentioned above unless otherwise stipulated after the meet and confer.
IT IS HEREBY REQUESTED that, subject to the Court's approval or setting of alternative dates consistent with the Court's calendar, the following case schedule shall govern:
Event Current Deadline Proposed New Deadline
Deadline for Completion of Fact
Discovery N/A June 29, 2018
Dispositive Motions Filing Deadline May 18, 2018 August 17, 2018
Oppositions to Dispositive Motions
Filing Deadline June 1, 2018 August 31, 2018
Replies In Support of Dispositive
Motions Filing Deadline June 8, 2018 September 7, 2018
Dispositive Motion Hearing Date June 28, 2018 at 2:00 p.m. September 27, 2018 at 2:00
p.m.
Exchange Witness Lists and Citations
to Evidence August 8, 2018 October 30, 2018
Motions in Limine Filing Deadline August 14, 2018 November 6, 2018
Joint Pretrial Statement and Proposed
Order, Proposed Jury Instructions, Voir August 21, 2018 November 13, 2018
Dire Questions, Verdict Forms,
Statement of Case, Trial Briefs, and
Oppositions to MIL Filing Deadline
Pretrial Conference September 4, 2018 at 3:00 November 27, 2018 at 3:00
p.m. p.m.
Trial September 17, 2018 @ 8:30 December 10, 2018 @ 8:30
a.m. a.m.
Pursuant to Civil Local Rule 5-1(i)(3), the filer of this document attests that all signatories have concurred in its filing.
ORDER
Pursuant to the joint request of the parties, and for goood cause shown, the case schedule is amended as follows:
Event Current Deadline Proposed New Deadline
Deadline for Completion of Fact N/A June 29, 2018
Discovery
Dispositive Motions Filing Deadline May 18, 2018 August 17, 2018
Oppositions to Dispositive Motions
Filing Deadline June 1, 2018 August 31, 2018
Replies In Support of Dispositive June 8, 2018 September 7, 2018
Motions Filing Deadline
Dispositive Motion Hearing Date June 28, 2018 at 2:00 p.m. September 27, 2018 at 2:00
p.m.
Exchange Witness Lists and Citations
to Evidence August 8, 2018 October 30, 2018
Motions in Limine Filing Deadline August 14, 2018 November 6, 2018
Joint Pretrial Statement and Proposed
Order, Proposed Jury Instructions, Voir August 21, 2018 November 13, 2018
Dire Questions, Verdict Forms,
Statement of Case, Trial Briefs, and
Oppositions to MIL Filing Deadline
Pretrial Conference September 4, 2018 at 3:00 November 27, 2018 at 3:00
p.m. p.m.
Trial September 17, 2018 @ 8:30 December 10, 2018 @ 8:30
a.m. a.m.
IT IS SO ORDERED.
