ERRATA TO STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER SUBMITTED IN COMPLIANCE WITH LR 26-1(b)

GEORGE FOLEY, Jr., Magistrate Judge.

SPECIAL SCHEDULING REVIEW REQUESTED

Pursuant to Local Rules 26-1(b), the parties respectfully submit the following revised stipulated discovery plan and jointly request that the Court: 1) approve this plan, and 2) implement the plan as a scheduling order. The FRCP 26(f) conference was held on September 9, 2016.

1. Subjects of Discovery

Discovery shall be conducted within the scope and limitations of Fed. R. Civ. P. 26(b).

2. Discovery Cut-Off Date

Defendant Superior Electrical, Mechanical & plumbing Inc. answered the Complaint and asserted a counter-claim against Plaintiffs on July 29, 2013. Plaintiffs/Counter-Defendants answered the counter-claim on August 19, 2016.

The parties request additional time in the amount of 180 days beyond the 180 days allowed for under the Federal Rules of Civil Procedure. The reason why additional time is needed and special discovery scheduling warranted is due to the following: The three Plaintiffs each allege that they sustained substantial injury due to Defendant's alleged negligence. The three Plaintiffs in this matter are still treating extensively for the injuries sustained in the subject motor vehicle accident. Additionally, the exact nature of Plaintiffs' injuries and their treatment status is unstable at this time. Moreover, given the number of parties, the potential need to add the driver/employee of Defendant once his or her identity becomes known, the number of medical expert depositions that will likely need to be taken as well as depositions of any retained experts, the voluminous amount of medical records and billing that will need to be produced and reviewed, and discovery necessary on Defendant/Counter Plaintiffs' counter-claims, the parties would not be able to realistically complete all of the discovery necessary in 180 days.

In short, the parties request the additional 180 days now to avoid having to inevitably move this Court for time in the near future. This request for additional time is not meant for the purposes of delay or with any dilatory motive. Therefore, discovery shall close on August 2, 2017.

3. Amendment of Pleadings and Adding Parties

Motions to amend pleadings and add parties shall be filed no later than ninety (90) days before the close of discovery: May 23, 2017.

4. Expert Disclosures

Expert disclosures shall be due no later than sixty (60) days before the close of discovery: June 22, 2017. Rebuttal disclosures shall be due no later than thirty (30) days before the close of discovery: July 21, 2017.

5. Interim Status Report

The Interim Status Report referenced in LR 26-3 shall be filed no later than sixty (60) days before the expiration of the discovery period: June 22, 2017.

6. Dispositive Motions

The deadline for filing dispositive motions shall be thirty (30) days after the close of discovery: September 20, 2017.

7. Joint Pre-Trial Order

The Joint Pre-Trial Order referenced in LR 26-1 (e)(5) shall be filed no later than thirty (30) days after the date set for filing dispositive motions: October 20, 2017. However, in the event that dispositive motions are filed, the date for filing a Joint Pre-Trial Order shall be suspended until thirty (30) days after a decision is rendered by the Court regarding the dispositive motions, or upon further order of the Court.

IT IS SO ORDERED.