[PROPOSED] STIPULATION AND ORDER TO EXTEND DISCOVERY

[FIRST REQUEST]

BRENDA WEKSLER, Magistrate Judge.

Pursuant to Fed. R. Civ. P. 26(f), and Local Rule 26-1, Plaintiffs Jeffrey K. Engler and Katherine M. Sennes-Engler ("Plaintiffs") and CMG Mortgage Inc. d/b/a CMG Financial ("CMG") (collectively the "Parties"), by and through their attorneys, hereby stipulate to extend discovery deadlines and other deadlines in the September 9, 2019 Scheduling Order as follows:

1. Completed Discovery.

The parties have exchanged initial and supplemental disclosures. Plaintiffs propounded written Interrogatories, Request for Admissions and Request for Documents ("Plaintiffs' Written Discovery Requests") to Defendant. Defendant has responded to Plaintiffs' Written Discovery Requests and produced documents. CMG's 30(b)(6) deposition has been noticed and the parties intend to proceed with deposition if this action is not settled.

2. Remaining Discovery.

Written discovery responses and at least one deposition.

3. Good Cause.

The parties have been diligently litigating this case and are requesting this extension for good cause because CMG's 30(b)(6) deposition is currently set for November 18, 2019. Defense counsel has requested this extension from Plaintiff's counsel due to a family death, causing defense counsel to be unavailable from November 15th-November 22nd. Furthermore, Plaintiff has proposed a settlement that involves CMG being required to, amongst other matters, modify pending mortgage obligations. CMG is in the process of considering the parameters of such a resolution.

This stipulation is made in good faith, is not interposed for delay, and is not filed for an improper purpose. This is also the parties' first request for an extension.

4. Current Discovery Deadlines.

5. Proposed Discovery Deadlines.

WHEREAS, no prejudice will occur to this Court or the Parties if granted, good cause supports this request to extend discovery;

NOW, THEREFORE, in consideration of the foregoing, and for good cause, IT IS HEREBY STIPULATED AND AGREED, by and between the Parties as follows:

The September 9, 2019 Scheduling Order shall be amended as follows:

IT IS SO STIPULATED.

ORDER GRANTING

STIPULATION TO EXTEND DISCOVERY

In consideration of the parties' stipulation and good cause showing, IT IS ORDERED THAT the September 9, 2019 Scheduling Order shall be amended as follows:

IT IS SO ORDERED.