Filed: Feb. 08, 2017
Latest Update: Feb. 08, 2017
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND INITIAL EXPERT DEADLINES [SECOND REQUEST] GEORGE FOLEY, Jr. , Magistrate Judge . Plaintiff TIMOTHY BOYTOR (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant"), by and through their respective counsel of record LLC and hereby stipulate to modify the scheduling order to extend the initial expert discovery deadlines by five (5) days. Pursuant to Local Rule 6-1(b), the parties hereby aver that this is the second
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND INITIAL EXPERT DEADLINES [SECOND REQUEST] GEORGE FOLEY, Jr. , Magistrate Judge . Plaintiff TIMOTHY BOYTOR (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant"), by and through their respective counsel of record LLC and hereby stipulate to modify the scheduling order to extend the initial expert discovery deadlines by five (5) days. Pursuant to Local Rule 6-1(b), the parties hereby aver that this is the second s..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND INITIAL EXPERT DEADLINES
[SECOND REQUEST]
GEORGE FOLEY, Jr., Magistrate Judge.
Plaintiff TIMOTHY BOYTOR (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant"), by and through their respective counsel of record LLC and hereby stipulate to modify the scheduling order to extend the initial expert discovery deadlines by five (5) days.
Pursuant to Local Rule 6-1(b), the parties hereby aver that this is the second such discovery extension requested in this matter.
DISCOVERY COMPLETED TO DATE
• The parties have conducted an FRCP 26(f) conference and have served their respective FRCP 26(a) disclosures;
• The parties have completed written discovery;
• Walmart has deposed Plaintiff;
• Depositions of fact witnesses/store employee
• FRCP 35 Independent Medical Examination of Plaintiff.
DISCOVERY TO BE COMPLETED AND REASONS FOR DISCOVERY
Discovery to be completed includes:
• Depositions of expert witnesses and treating medical providers;
• Initial Expert Disclosures
• Rebuttal expert disclosures.
The parties aver, pursuant to Local Rule 2.25, that good cause exists for the requested extension. The parties agree that, pending this Court's approval, extension of initial expert disclosure deadlines is appropriate, as the parties wish to further investigate this case, conduct necessary discovery prior to pertinent deadlines, and potentially reach a resolution prior to incurring fees and costs for extensive discovery and experts. Despite the good faith efforts of the parties to comply with the Court's discovery deadlines, Defendant's expert's availability for a preparation of expert reports necessitates this extension. All amendments are noted in "BOLD."
[PROPOSED] NEW DISCOVERY DEADLINES
Initial Expert Disclosure Deadline
Currently: February 6, 2017
Proposed: February 10, 2017
If the extension is granted, all anticipated additional discovery is expected to be included within the stipulated extended deadline. The parties aver that this request for extension is made by the parties in good faith and not for the purpose of delay.
ORDER
IT IS SO ORDERED.
