STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

(Second Request)

CAM FERENBACH, Magistrate Judge.

COMES NOW, Plaintiff, PAMELA GROGAN, by and through her counsel of record, MARK G. HENNESS, ESQ. and JACOB S. SMITH, ESQ. of the law firm of HENNESS & HAIGHT and Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, by and through its counsel of record, BENJAMIN J. CARMAN, ESQ. of the law firm of RANALLI ZANIEL FOWLER & MORAN, and submit the following stipulation and order to extend discovery deadlines pursuant to LR 26-4 as follows:

1. Summary of Discovery Completed

All parties have provided initial witness lists and documents pursuant to FRCP 26 and supplements thereto. Plaintiff has executed authorizations served by Defendant. Plaintiff and Defendant had both served written discovery requests on each other, and both parties have responded to the same. Plaintiff is presently working to schedule the depositions of State Farm Adjuster, Kim Korich, as well as the 30(b)(6) witness(es) of State Farm. Plaintiff's deposition is presently set for April 25, 2018.

2. Discovery Remaining

The depositions of Plaintiff and Plaintiff's treating doctors must be completed, in addition to the depositions of State Farm Adjuster Kim Korich and other State Farm designees and witnesses, as necessary. Additionally, non-party witnesses and the parties' expert witnesses (once disclosed) need to be taken. To the extent necessary, the parties may also seek to propound additional written discovery and/or follow up on the discovery already propounded.

3. Reason Why Discovery Was Not Completed

Discovery in this matter is currently scheduled to close on June 3, 2018. Additional time is required to work through scheduling issues so that discovery may be completed. Specifically, the parties require additional time in order to coordinate the depositions of the Defendant's employees and corporate representatives. For example, Kim Korich, the claims adjuster who handled the subject claim, is no longer an employee of Defendant State Farm. Because she is not able to take leave during business hours at her new employer, Ms. Korich has requested that her deposition be scheduled for after 6pm or on a Saturday. Plaintiff's counsel is agreeable to accommodating this request, but needs additional time to make schedule arrangements for an after-hours deposition. Moreover, as Plaintiff would like to have Ms. Korich's deposition testimony prior to expert disclosures, the present dates needed to be moved back. This is the parties' second request for an extension of discovery deadlines in this matter; therefore, the parties have agreed to an extension of the discovery deadlines by 45 days to enable them to complete the remaining discovery.

4. Proposed Schedule for Completing Discovery

Accordingly, the parties respectfully request that this Court enter an order setting the following discovery plan and scheduling order dates:

Counsel further states that the requested extension of the discovery deadline is not intended for purposes of delay, but rather for the purposes set forth hereinabove.

ORDER

IT IS SO ORDERED.