STIPULATION AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES

(First Request)

PEGGY A. LEEN, Magistrate Judge.

The parties, by and through their respective counsel of record, hereby stipulate and agree as follows:

1. On December 15, 2017, this Court entered an Order granting the Stipulated Discovery Plan and Scheduling Order submitted by the parties.

2. This is the first request by the parties to amend the Court's December 15, 2017 Scheduling Order.

3. The parties stipulate and agree to extend the discovery deadline for thirty (30) days from May 14, 2018 up to and including June 13, 2018, for the sole purpose of allowing the parties to complete deposition discovery. All written discovery must be served such that responses are due no later than May 14, 2018.

4. The parties further agree to extend the due date for dispositive motions to thirty (30) days after the proposed new close of discovery.

STATEMENT OF DISCOVERY THAT HAS BEEN COMPLETED

The parties have been diligently pursuing discovery. To date, they have exchanged initial disclosures, including relevant documents. In addition, the parties have exchanged written document requests and interrogatories.

Plaintiff served the following disclosures:

Defendant served the following disclosures:

Plaintiff served the following discovery requests:

a. First Set of Request for Production of Documents. Defendant responded on February 7, 2018.

b. First Set of Interrogatories. Defendant responded on February 7, 2018.

c. Plaintiff has identified five deposition she seeks to complete.

Defendant served the following discovery requests:

a. First Set of Interrogatories. Plaintiff's response is due on March 30, 2018.

b. First Set of Request for Production of Documents. Plaintiff's response is due on March 30, 2018.

c. Defendant has set Plaintiff's deposition for May 9, 2018.

STATEMENT OF DISCOVERY THAT REMAINS TO BE COMPLETED

The parties are currently in the process of scheduling depositions. To accommodate counsel, including third party deponents' schedules, the parties seek until June 13, 2018 to ensure completion of these depositions. For the above stated reasons, the parties request that the deadline to complete depositions be extended for thirty (30) days from May 14, 2018 to June 13, 2018.

PROPOSED SCHEDULE

The parties stipulate and agree that:

1. Discovery: The discovery period shall be extended thirty (30) days from May 14, 2018 to June 13, 2018, for the sole purpose of allowing the parties to complete deposition discovery. All written discovery must be served such that responses are due no later than May 14, 2018.

2. Dispositive Motions: The dispositive motions deadline shall be extended thirty (30) days from June 13, 2018 to July 13, 2018.

4. Pre-Trial Order: If no dispositive motions are filed, the Joint Pretrial Order shall be filed thirty (30) days after the date set for the filing of dispositive motions, which is August 13, 2018. In the event dispositive motions are filed, the date for filing the Joint Pretrial Order shall be suspended until thirty (30) days after decision on the dispositive motions or by further order of the Court.

This stipulation and order is sought in good faith and not for the purpose of delay. No prior request for any extension of scheduling deadlines has been made.

ORDER

IT IS SO ORDERED.