JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY

CARL W. HOFFMAN, Magistrate Judge.

Plaintiff David Lucero ("Plaintiff") and Defendant Smith-Palluck Associates Corp. d/b/a Las Vegas Athletic Clubs ("Defendant") (jointly as "the Parties"), by and through their counsel of record, do hereby stipulate to modify the Court's Order, ECF No. 11, to extend (1) the last date to complete discovery from January 5, 2018, to March 6, 2018; (2) the last date to file dispositive motions from February 5, 2018, to April 6, 2018; and (3) the last date to file the proposed joint pretrial order from March 7, 2018, to May 7, 2018.

Pursuant to LR 26-4, good cause exists to amend the Scheduling Order. The Parties have diligently pursued discovery. Plaintiffs have propounded written discovery requests and have noticed Defendant's deposition. The Parties are now rescheduling Plaintiffs' deposition of Defendant. This request for extension of deadlines is made specifically in this fee-shifting matter since the taking of depositions are a significant expense. The Parties have run into limitations based on the availability of Defendant's person most knowledgeable.

Further good cause exists to amend the Scheduling Order to provide additional time to complete settlement discussions.

Pursuant to LR 26-4(a), Plaintiffs have propounded written discovery requests upon Defendant and have noticed the deposition of Defendant. Defendant served Plaintiffs with objections to Plaintiffs' written discovery requests.

Pursuant to LR 26-4(b), the Parties request additional time to conduct Plaintiffs' deposition of Defendant and to confer regarding certain discovery matters.

Pursuant to LR 26-4(c), this request for extension of deadlines is made specifically in this fee-shifting matter since the taking of a deposition is a significant expense. The Parties have run into limitations based on the availability of Defendant's person(s) most knowledgeable.

Pursuant to LR 26-4(d), the Parties propose the following discovery schedule: (1) the last date to complete discovery shall be March 6, 2018; (2) the last date to file dispositive motions shall be April 6, 2018; and (3) the last date to file the proposed joint pretrial order shall be May 7, 2018.

For the foregoing reasons, the Parties jointly request that this Court modify its September 18, 2017 Order to provide an additional 60 days to complete discovery, and the in the ordinary course file dispositive motions, and the proposed joint pretrial order as described in the proposed timeline above.

This is the Parties' first request for an extension of these deadlines. DATED this 30th day of November 2017.

ORDER

IT IS HEREBY ORDERED that the Order, ECF No 11, is modified to extend the discovery deadlines as follows: (1) the last date to complete discovery shall be March 6, 2018; (2) the last date to file dispositive motions shall be April 6, 2018; and (3) the last date to file the proposed joint pretrial order shall be May 7, 2018.

IT IS SO ORDERED.