STIPULATED MOTION TO EXTEND CASE DEADLINES

SHEILA K. OBERTO, Magistrate Judge.

Plaintiff Societe D'Equipments Internationaux Nigeria, Ltd. ("SEI"), Defendant Ara G. Dolarian ("Dolarian"), and Defendant Dolarian Capital, Inc. ("DCI") hereby stipulate to an extension of the following deadlines, and hereby make this Stipulated Motion:

SEI, Dolarian, and DCI make this stipulated motion with respect to the following facts:

WHEREAS, the Court's Scheduling Order of November 2, 2017, provides the following deadlines:

(Declaration of R. Jeffrey Warren ["Warren Decl."], ¶ 4.)

WHEREAS, since the October 26, 2017 Scheduling Conference, DCI and SEI have engaged in an initial exchange of written discovery requests (Declaration of R. Jeffrey Warren ["Warren Decl."], ¶ 5);

WHEREAS, SEI served its responses to DCI's discovery requests on December 27, 2017 (Warren Decl., ¶ 6,);

WHEREAS, on January 16, 2018, DCI served three meet-and-confer letters concerning alleged deficiencies in SEI's discovery responses served on December 27, 2017 (Warren Decl., ¶ 7.);

WHEREAS, DCI served its responses to SEI's discovery requests on January 19, 2018 and produced documents (Warren Decl., ¶ 8.);

WHEREAS, upon review of DCI's responses, counsel for SEI believes some of DCI's responses deficient, but has not formally met-and-conferred with DCI (Warren Decl., ¶ 9.);

WHEREAS, DCI has been attempting to schedule the depositions of (1) SEI's Person Most Knowledgeable and (2) Hima Aboubakar since November 2017 (Warren Decl., ¶ 10.);

WHEREAS, DCI honored SEI's request that the deposition of SEI's Person Most Knowledgeable be scheduled for January 23, 2018 (Warren Decl., ¶ 11.);

WHEREAS, on January 19, 2018, SEI informed its counsel that its Person Most Knowledgeable would not appear at the January 23 deposition (Warren Decl., ¶ 12.);

WHEREAS, Mr. Aboubakar has demanded that his deposition be taken, if at all, in Niamey, Niger (Warren Decl., ¶ 13.);

WHEREAS, the parties are attempting to meet-and-confer amongst themselves and with Mr. Aboubakar as to the location of the deposition—the United States Department of State has issued a travel advisory to Americans regarding travel to Niger (Warren Decl., ¶ 14.);

WHEREAS, in view of DCI's discovery responses and document production of January 19, 2018, SEI's counsel believes a deposition of DCI's Person Most Knowledgeable may be warranted (Warren Decl., ¶ 15.);

WHEREAS, on January 12, 2018, the parties served their respective Expert Witness Disclosures (Warren Decl., ¶ 16.);

WHEREAS, no party has noticed the deposition of any of the designated experts (Warren Decl., ¶ 17.);

WHEREAS, on January 23, 2018, SEI's counsel filed a Motion to Withdraw from its representation of SEI in this matter on the bases that (a) there has been a breakdown in communication between SEI and its counsel such that it has become unreasonably difficult for its counsel to carry out its representation effectively; and (b) SEI is in breach of its obligations under its retainer agreement, and there is now a deficit of $39,612.31 in outstanding fees and costs, plus an additional $10,893.75 in expert witness costs (See ECF No. 136) (Warren Decl., ¶ 18.);

WHEREAS, in view of the foregoing, the following issues remain outstanding: (a) the sufficiency of SEI's discovery responses served on December 27, 2017; (b) the sufficiency of DCI's discovery responses served on January 19, 2018; (c) the deposition of SEI's Person Most Knowledgeable; (d) the deposition of Hima Aboubakar; (e) the potential deposition of DCI's Person Most Knowledgeable; (f) the depositions of the parties' respective designated experts; and (g) SEI's counsel's Motion to Withdraw (Warren Decl., ¶ 19.)

WHEREAS, the parties agree that (a) certain existing deadlines and scheduled dates may not provide the parties sufficient time to resolve the current outstanding issues, meaningfully participate in potential settlement discussions, or to bring any unresolved disputes to the Court for resolution, and (b) a brief continuance is warranted to facilitate the transition of SEI's counsel and to avoid prejudice to any party (Warren Decl., ¶ 20.);

WHEREAS, the requested extension will not require a continuance of either the Pre-Trial Conference set for June 13, 2018 or the Trial Date set for August 7, 2018 (Warren Decl., ¶ 21.); and

WHEREAS, the parties request that the Court schedule a Status Conference to ascertain the status of SEI's retention of new counsel soon after the Court rules upon SEI's counsel's Motion to Withdraw (Warren Decl., ¶ 22.).

STIPULATION

THEREFORE, it is hereby stipulated and agreed by the parties, that the following deadlines are extended as follows:

IT IS HEREBY STIPULATED.

ORDER

Before the Court is the parties' above-Stipulation to Extend Case Deadlines. (Doc. 137.) The parties indicate in the Stipulation that their requested modifications to the schedule are necessary to provide the parties sufficient time to resolve the outstanding discovery issues and to resolve Plaintiff's counsel's Motion to Withdraw as Attorney for Plaintiff. For good cause shown, pursuant to Fed. R. Civ. P. 16(b)(4), the Court hereby GRANTS the Stipulation and modifies its November 2, 2017, Scheduling Order (Doc. 130) as follows:

IT IS SO ORDERED.