Filed: Jan. 09, 2018
Latest Update: Jan. 09, 2018
Summary: STIPULATION AND REQUEST TO EXTEND DISCOVERY AND OTHER DEADLINES (Third Request) CARL W. HOFFMAN , Magistrate Judge . COME NOW, Plaintiff, named above, by and through his counsel of record, MICHAEL P. BALABAN, ESQ., and Defendant, named above, by and through its attorneys of record, MYRNA L. MAYSONET, ESQ., CHERISH A BENEDICT, ESQ., and PHILLIP A. SILVESTRI, ESQ., pursuant to Local Rule 26-4, and herein stipulate, agree and make joint application to extend the discovery cut-off and related
Summary: STIPULATION AND REQUEST TO EXTEND DISCOVERY AND OTHER DEADLINES (Third Request) CARL W. HOFFMAN , Magistrate Judge . COME NOW, Plaintiff, named above, by and through his counsel of record, MICHAEL P. BALABAN, ESQ., and Defendant, named above, by and through its attorneys of record, MYRNA L. MAYSONET, ESQ., CHERISH A BENEDICT, ESQ., and PHILLIP A. SILVESTRI, ESQ., pursuant to Local Rule 26-4, and herein stipulate, agree and make joint application to extend the discovery cut-off and related d..
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STIPULATION AND REQUEST TO EXTEND DISCOVERY AND OTHER DEADLINES
(Third Request)
CARL W. HOFFMAN, Magistrate Judge.
COME NOW, Plaintiff, named above, by and through his counsel of record, MICHAEL P. BALABAN, ESQ., and Defendant, named above, by and through its attorneys of record, MYRNA L. MAYSONET, ESQ., CHERISH A BENEDICT, ESQ., and PHILLIP A. SILVESTRI, ESQ., pursuant to Local Rule 26-4, and herein stipulate, agree and make joint application to extend the discovery cut-off and related dates for a period of ninety (90) days up to and including Monday, April 30, 2018. The present discovery cut-off date is January 29, 2018, and no calendar call date or trial date has been set.
This request is being made timely in accordance with LR 26-4 and the prior scheduling Order, which provides that requests for further discovery extensions must be made no later than twenty-one (21) days before the existing discovery cut-off date, or, here, by January 8, 2018. This is the third request for an extension.
To date the parties have both made their initial disclosures to the other side and Defendant has propounded written discovery to Plaintiff and Plaintiff has propounded written discovery to Defendant. In addition, Defendant intendcs to depose Plaintiff, and Plaintiff intends to depose Kit Quirante, Frank D'Agati, Dan Piccolo, Carolyn McKay, Rolando Betuicci, Robert Stubson and Raymond Lujan, who are mostly former employees of Defendant and need to be located and contacted. In addition, counsel for both parties have other cases before this Court, which involve overlapping witnesses to some extent and, thus, the attorneys for both parties are coordinating the scheduling of the depositions in such cases to minimize the burden on the witnesses and travel for out-of-state counsel.
The parties and their attorneys have diligently worked to complete discovery as expediently as possible and will continue to try to complete the remaining discovery in as expedient a manner as possible.
Given the above, the parties request that the discovery period be extended as follows:
Activity Former Date Requested Date
Discovery Cut-Off Date 01/29/18 04/30/18
Dispositive Motions 02/26/18 05/29/18
Pretrial Order 03/28/18 06/26/181
In accordance with LR 26-4 the parties understand that any further requests for discovery extensions must be made no later than twenty-one (21) days before the new proposed discovery cut-off date of April 30, 2018, or no later than twenty-one (21) days before any other deadline sought to be extended.
IT IS SO ORDERED.
