JOINT REQUEST FOR EXTENSION OF SCHEDULING DEADLINES

RICHARD F. BOULWARE, II, District Judge.

The Parties, through their undersigned counsel, respectfully request the Court extend the discovery Motion and briefing deadlines set forth in the Court's Order dated August 18, 2017 and would state in support thereof as follows

1. Pursuant to the Court's Order, Plaintiffs were provided the opportunity to conduct discovery necessary to support its jurisdictional allegations. Said discovery would include in part, three depositions. In this matter, said depositions are corporate depositions of the defendant agency and two other large corporate entities. Document production has been requested as well. The parties have conferenced and coordinated the deposition of several representatives, locations, availability and document production. The document production involves obtaining some records stored off site and requires a detailed review of documents in order to determine relevant material.

2. The Parties have conducted several scheduling telephone conferences which have included third party Noridian Healthcare Solutions, the Medicare Administrative Contractor responsible for processing many of the claims described in the Amended Complaint. This third party will also be producing corporate representatives for deposition. Defendant will be producing its representatives in Baltimore, Maryland. A third corporate deposition of a Qualified Independent Contractor for Defendant is currently being arranged.

3. During this process Hurricane Irma had a significant impact on Florida, including evacuations in Plaintiffs' counsels' area resulting in a 10-14 day delay in operations.

4. Document production prior to deposition and availability of deponents currently necessitates scheduling deposition dates for mid-November into December, 2018.

5. Even with extensive coordination of opposing counsel and counsel for outside entities, the ninety (90) day window of opportunity to conduct the discovery in question provided by the Court Order does not appear feasible under the circumstances. Therefore, the Parties respectfully request the Court extend the deadline for discovery through December 15, 2017 and reset the deadlines for filing dispositive motions and briefing.

6. Under the Court's August 18, 2017 Order, briefing on dispositive motions is scheduled to commence on December 8. In order to complete discovery, and afford the Parties the time necessary to prepare the necessary memorandum accompanying dispositive motions, the Parties respectfully request the Court enter a revised scheduling order setting a new due date for dispositive motions to be filed on or before January 26, 2018, responses on February 16, 2018, and replies on March 9, 2018.

PROPOSED ORDER

Upon consideration of the Parties' Joint Request for Extension of Scheduling Deadlines, it is HEREBY ORDERED:

Discovery shall remain OPEN through December 15, 2017;

IT IS FURTHER ORDERED that dispositive motions shall be due January 26, 2018, Responses due February 16, 2018, with Replies due March 9, 2018.

IT IS SO ORDERED: