Joint Stipulation and Order to Extend Discovery (First Request)

PEGGY A. LEEN, Magistrate Judge.

Plaintiffs Keith H. Asbell ("Plaintiff") and Experian Information Solutions, Inc. ("Defendant" and together with Plaintiff as the "Parties") by and through their counsel of record hereby stipulate to modify the Court's Order, ECF No. 13, to extend:

Pursuant to LR 26-4, good cause exists to amend the Scheduling Order. The Parties have diligently engaged in written discovery. Plaintiff has propounded written discovery requests and is continuing to meet and confer with Defendant regarding documents withheld because of the lack of a Protective Order (which has since been entered). As set forth in Defendant's discovery responses, it agreed to supplement upon entry of the protective order and will do so. Experian has also served written discovery requests to Plaintiff.

The Parties ran into scheduling conflicts with Experian's Rule 30(b)(6) witness and Plaintiff has now noticed Experian's deposition for June 1, 2018. Experian's witness is not available on June 1st, and Experian will provide Plaintiff with alternative dates. Experian has noticed Plaintiff's deposition for July 16, 2018. To the extent that date does not work for Plaintiff, Experian will endeavor to find a mutually convenient date for the parties. Plaintiff will seek to disclose an expert after Defendant's deposition and there is therefore good cause to extend the expert disclosure deadline until after Defendant discloses its documents and after Defendant's deposition. Plaintiff will also now seek third party discovery from Wells Fargo Home Mortgage since Experian is denying it received credit reporting from Wells Fargo Home Mortgage. The Parties are also actively discussing resolution of this case. This request for extension of deadlines is made specifically in this feeshifting matter since the taking of depositions are a significant expense. The Parties ran into limitations based on the availability of Experian for deposition and therefore seek to extend the discovery deadlines by 30 days.

Pursuant to LR 26-4(a), as set forth above, Plaintiff has propounded written discovery requests on Defendant, Defendant has propounded discovery on Plaintiff. The Parties have noticed each others' depositions.

Pursuant to LR 26-4(b), the Parties request additional time to continue to meet and confer about discovery documents, third party discovery relating to Wells Fargo's credit reporting history, and to conduct depositions and disclose experts, as necessary.

Pursuant to LR 26-4(d), the Parties propose the following discovery schedule:

For these reasons, the Parties jointly request that this Court modify the Scheduling Order to provide an additional 30 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.

ORDER

IT IS HEREBY ORDERED that the Order, ECF No 13, is modified to extend the discovery deadlines as follows:

IT IS SO ORDERED.