ORDER

CAROL MIRANDO, Magistrate Judge.

This matter comes before the Court upon review of Plaintiff's Motion to Extend Discovery and All Trial and Pretrial Deadlines filed on October 5, 2018. Doc. 16. Plaintiff requests a 90-day extension of the remaining deadlines in the Case Management and Scheduling Order ("CMSO") due to delays in discovery and ongoing discovery disputes. Id. at 1-4. Defendant filed a response in partial opposition on October 8, 2018. Doc. 18. Defendant agrees that the remaining deadlines in the CMSO should be extended, but requests that the Court extend the time for written discovery by thirty days, depositions by sixty days, and all other deadlines by sixty days. Id. at 1. For the reasons stated below, Plaintiff's motion is granted.

Rule 16 requires a showing of good cause for modification of a court's scheduling order. Fed. R. Civ. P. 16(b)(4). "The diligence of the moving party should be considered in determining whether there is good cause to extend a deadline." Jozwiak v. Stryker Corp., No. 6:09-cv-1985-Orl-19GJK, 2010 WL 743834, at *2 (M.D. Fla. Feb. 26, 2010). In other words, the moving party must demonstrate it could not meet the deadline despite its diligent efforts. Sosa v. Airprint Sys., Inc., 133 F.3d 1417, 1418 (11th Cir. 1998); Idearc Media Corp. v. Kimsey & Assocs., P.A., No. 807-CV-1024-T-17EAJ, 2009 WL 413531, at *2 (M.D. Fla. Feb. 18, 2009). District courts have broad discretion (1) when managing their cases, including discovery and scheduling; and (2) in applying their local rules. Johnson v. Bd. of Regents of Univ. of Ga., 263 F.3d 1234, 1269 (11th Cir. 2001); see Reese v. Herbert, 527 F.3d 1253, 1267-68 (11th Cir. 2008); Johnson v. England, 350 F. App'x 314, 315-16 (11th Cir. 2009).

Here, Plaintiff seeks to extend the discovery deadline and subsequent trial and pre-trial deadlines1 in the CMSO (Doc. 15) by ninety days, as indicated below:

Plaintiff argues good cause exists because Defendant provided insufficient discovery answers in response to Plaintiff's initial written discovery (served on April 27, 2018), objected to providing basic information, and only began producing responsive documents on August 31, 2018, about a month before the discovery deadline. See id. at 3-4; Doc. 15. Plaintiff states Defendant produced hundreds of additional and inappropriately redacted documents as late as October 4, 2018. Doc. 16 at 4. Plaintiff argues she has been "very diligent" in prosecuting the case but has been unable to schedule any depositions due to the "extensive delay" in obtaining complete discovery responses from Defendant. Id. at 5. Defendant agrees that extensions are needed but not to the extent requested by Plaintiff. Doc. 18 at 1. Defendant claims Plaintiff could have scheduled depositions despite the lack of complete discovery answers and notes that Plaintiff failed to include a memorandum of law with the motion. Id. at 2-3. Defendant also filed a motion to compel on October 5, 2018, seeking an order compelling Plaintiff to produce responsive documents to certain requests for production. See generally Doc. 17.

Given the extensive delays in discovery for which both parties appear partly responsible, the upcoming federal holidays and the fact that Defendant agrees at least some extensions are appropriate, the Court finds good cause to extend the discovery deadline and the remaining CMSO deadlines that have not yet passed by 90 days. Due to the procedural posture of the case and the nature of the relief requested, the Court also finds good cause to excuse Plaintiff's failure to include a memorandum of law required by Local Rule 3.09.

ACCORDINGLY, it is

ORDERED:

1. Plaintiff's Motion to Extend Discovery and All Trial and Pretrial Deadlines (Doc. 16) is GRANTED.

2. An amended case management and scheduling order will be issued by separate Order.

DONE and ORDERED.