STIPULATION TO EXTEND DEADLINE FOR FILING AND RESPONDING TO MOTION FOR SUMMARY JUDGMENT; ORDER THEREON

HAYWOOD S. GILLIAM, Jr., District Judge.

WHEREAS, at the May 19, 2015 Case Management Conference ("CMC"), the parties informed the Court that: (a) they had not yet started discovery because the Rule 26 conference was held a short time earlier; and (b) if there were no discovery disputes and the parties were able to receive all necessary discovery, they would be in a position to file or defend against a motion for summary judgment related to Plaintiff's individual claims within in a few months of the CMC;

WHEREAS, based upon the foregoing, the Court set an August 19, 2015 deadline for the parties to bring a summary judgment motion relating to Plaintiff's individual claims;

WHEREAS, the parties have propounded and engaged in discovery directly after the CMC;

WHEREAS, counsel for both parties were traveling and unavailable at different times during July, 2015, which made it impossible to conduct depositions that month;

WHEREAS, the parties have had discovery disputes relating to written discovery and depositions since the CMC. The parties are continuing to engage in meet and confer discussions relating to Rule 30(b)(6) deposition topics and written discovery. The parties may need to file a joint discovery brief with the Court to address certain issues. After the issues are resolved, Plaintiff will need to take the Rule 30(b)(6) deposition; and

WHEREAS, the Parties need additional time to obtain the necessary discovery to bring or defend against a motion for summary judgment pursuant to Federal Rule of Civil Procedure, Rule 56(d).

IT IS HEREBY STIPULATED as follows:

ORDER

For good cause shown, the Court hereby orders that the deadline for Plaintiff to respond to Defendant's Motion for Summary Judgment (Dkt. No. 22) is November 2, 2015.