Filed: May 09, 2018
Latest Update: May 09, 2018
Summary: FIRST STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES GEORGE FOLEY, JR. , Magistrate Judge . Pursuant to LR IA 6-1 and LR 26-4, the parties, by and through their respective counsel, hereby stipulate and request that this Court extend the deadline for discovery in the above-captioned matter for forty-five (45) days, or up to and including September 6, 2018. DISCOVERY COMPLETED: • Plaintiff has served her Initial Disclosures and supplements thereto. • Defendant has served its Initial
Summary: FIRST STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES GEORGE FOLEY, JR. , Magistrate Judge . Pursuant to LR IA 6-1 and LR 26-4, the parties, by and through their respective counsel, hereby stipulate and request that this Court extend the deadline for discovery in the above-captioned matter for forty-five (45) days, or up to and including September 6, 2018. DISCOVERY COMPLETED: • Plaintiff has served her Initial Disclosures and supplements thereto. • Defendant has served its Initial ..
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FIRST STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
GEORGE FOLEY, JR., Magistrate Judge.
Pursuant to LR IA 6-1 and LR 26-4, the parties, by and through their respective counsel, hereby stipulate and request that this Court extend the deadline for discovery in the above-captioned matter for forty-five (45) days, or up to and including September 6, 2018.
DISCOVERY COMPLETED:
• Plaintiff has served her Initial Disclosures and supplements thereto.
• Defendant has served its Initial Disclosures and supplements thereto.
• Defendants have served subpoenas duces tecums to all of Plaintiff's medical providers.
• Plaintiff's deposition has been taken.
• Plaintiffs have served and responded to written discovery.
• Defendants have served and responded to written discovery.
REMAINING DISCOVERY TO BE COMPLETED:
• Initial and rebuttal expert disclosures;
• Fact and expert witness depositions; and
• Any additional written discovery that may be necessary following this discovery.
REASONS WHY EXTENSION REQUESTED:
On May 7, 2018, Plaintiff was informed that her medical expert was no longer able to prepare a report due to his father being ill and the expert consequently needing to be out of the country for an extended period of time. Due to the extent of Plaintiff's claimed injuries, it is not feasible for Plaintiff to retain another expert — and for that expert to effectively write a report — by the current expert disclosure deadline, which is 17 days away. Plaintiff is diligently working to retain a new expert and to get the relevant records to a new expert to reduce any delay.
Based on foregoing, good cause exists to extend the discovery deadline to allow Plaintiffs to take these outstanding depositions.
PROPSED SCHEDULE FOR REMAINING DEADLINES:
The following is a list of the current deadlines and the parties' proposed extended deadlines:
Current Proposed
DiscoveryCut-Off 7/23/2018 9/6/2018
ExpertDisclosure 5/24/2018 7/6/2018
RebuttalDisclosures 6/25/2018 8/6/2018
DispositiveMotions 8/22/2018 10/5/2018
Pre-TrialOrder 9/21/2018 11/6/2018
This is the first request for extension of time in this matter. The parties respectfully submit that the reasons set forth above constitute "good cause" justifying the extension.
Wherefore, the parties respectfully request that this Court extend the discovery period by forty-five (45) days from the current deadline of July 23, 2018, up to an including September 6, 2018, and the other discovery dates as outlined in accordance with the list above.
IT IS SO ORDERED.
