STIPULATION AND ORDER TO EXTEND DISCOVERY (FIRST REQUEST)

CAM FERENBACH, Magistrate Judge.

All of the parties hereto, and for good cause described in this stipulation, and in accord with Local Rule 6-1 and Local Rule 26-4, the parties hereby request this Honorable Court to adopt and approve this stipulated extension to the discovery plan, and continue the discovery deadlines for 90 days as requested herein.

I. LOCAL RULE 6-1 IS SATISFIED

This is the first request for extension of discovery deadlines filed by the parties. Pursuant to the Stipulated Discovery Plan and Order dated March 9, 2018, the following dates govern for purposes of discovery:

The parties have been working in good faith to reach an amicable resolution. However, Plaintiff is still undergoing medical treatment and as such, is in the process of compiling complete information for initial disclosures and supplying requested HIPPA authorizations. As such, the parties need additional time to prepare for the disclosure of initial experts. Accordingly, the parties are requesting a 90-day extension to all discovery deadlines.

The instant request comports with Local Rule 6-1, in that no request is being made after the expiration of the specified period.

II. LOCAL RULE 26-4 IS SATISFIED

The instant request to extend discovery deadlines satisfies the requisites of Local Rule 26-4. While the deadline for motions to amend pleadings and add parties is less than 21 days away, all other deadlines are more than twenty-one (21) days from the filing of the instant stipulation and order.

Additionally, good cause exists for the extension. While the parties would like to reach a settlement, Plaintiff is still undergoing medical treatment and the parties require additional time to conduct discovery in preparation for initial expert disclosures. Defendant is still awaiting Plaintiff's initial disclosures and HIPPA authorizations, and additional time is required to issue subpoenas, schedule depositions and to complete discovery. As a result, the parties have requested all discovery deadlines be extended 90 days.

Listed below is a statement specifying the discovery completed in this case:

The parties are attempting to work towards settlement. However, as Plaintiff is still undergoing medical treatment, it is necessary to extend the discovery deadlines so the parties can procure additional records, obtain experts, and schedule depositions.

Finally, under Local Rule 26(4), it is necessary to articulate a proposed schedule for completing all remaining discovery. The parties are requesting an additional 90 days be afforded for discovery.

The following deadlines are requested.

The parties hereby stipulate to the proposed changes in the discovery deadlines.

ORDER

IT IS SO ORDERED:

The STIPULATION AND ORDER TO EXTEND DISCOVERY (FIRST REQUEST).