Filed: Feb. 08, 2018
Latest Update: Feb. 08, 2018
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY AND OTHER DEADLINES (FIRST REQUEST) GEORGE FOLEY, JR. , Magistrate Judge . Pursuant to LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case sixty (60) days, up to and including April 30, 2018. In addition, the parties request that the dispositive motions and pretrial order deadlines be extended in accordance with the discovery extension as
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY AND OTHER DEADLINES (FIRST REQUEST) GEORGE FOLEY, JR. , Magistrate Judge . Pursuant to LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case sixty (60) days, up to and including April 30, 2018. In addition, the parties request that the dispositive motions and pretrial order deadlines be extended in accordance with the discovery extension as o..
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STIPULATION AND ORDER TO EXTEND DISCOVERY AND OTHER DEADLINES
(FIRST REQUEST)
GEORGE FOLEY, JR., Magistrate Judge.
Pursuant to LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case sixty (60) days, up to and including April 30, 2018. In addition, the parties request that the dispositive motions and pretrial order deadlines be extended in accordance with the discovery extension as outlined herein. In support of this Stipulation and Request, the parties state as follows:
1. On June 16, 2017, Plaintiff filed her Complaint (ECF No. 1).
2. On September 1, 2017, Defendant filed its Answer to the Complaint (ECF No. 13).
3. On October 10, 2017, the parties prepared and filed their Proposed Discovery Plan and Scheduling Order (ECF No.16). The Court approved and entered the Discovery Plan and Scheduling Order on October 11, 2017 (ECF No. 17).
4. Defendant produced served its initial disclosures pursuant to Rule 26(a)(1) on November 6, 2017. Plaintiff served her initial disclosures pursuant to Rule 26(a)(1) on November 16, 2017.
5. Defendant served written discovery requests (Interrogatories and Requests for Production of Documents) to Plaintiff on November 14, 2017. Plaintiff responded to the Interrogatories on December 29, 2017 and to the Requests for Production on January 2, 2018.
6. The parties participated in an Early Neutral Evaluation ("ENE") on November 16, 2017.
7. Plaintiff provided First Supplemental Responses to Defendant's Interrogatories, First Supplemental Responses to Defendant's Requests for Production and First Supplemental Disclosures on January 16, 2018.
8. Plaintiff provided Second Supplemental Responses to Defendant's Requests for Production and Second Supplemental Disclosures on January 18, 2018.
9. Plaintiff propounded Interrogatories and Requests for Production of Documents on Defendant on January 18, 2018. Defendant is in the process of obtaining information to respond to these written discovery requests.
10. Plaintiff's deposition was scheduled to be taken on several occasions but has been continued due to conflicts with Plaintiff's work schedule and most recently as a result of an illness in the family of a Sunrise representative assisting in the defense of this matter.
DISCOVERY REMAINING
1. Defendant intend to provide responses to Plaintiff's written discovery on February 20, 2018, unless additional time is required.
2. Defendant intends to take Plaintiff's deposition at the end of February or during the first week of March, 2018.
3. The parties will take the depositions of any and all other necessary witnesses as determined through discovery.
4. The parties will issue and respond to any necessary additional written discovery.
This Request for an extension of time is not sought for any improper purpose or other purpose of delay. Rather, it is sought by the parties solely for the purpose of allowing sufficient time to finish necessary discovery.
WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED
As indicated above, Plaintiff's deposition has been postponed on two occasions, initially as a result of a conflict with Plaintiff's work schedule and most recently as a result of an illness in the family of a Sunrise representative who is assisting with the defense of this matter. An additional 60 days will allow the parties to take depositions and follow up with any necessary written discovery within the time frame of the extension.
In light of these circumstances, the parties require the brief requested extension in order to complete discovery. The following is a list of the current discovery deadlines and the parties' proposed extended deadlines.
Scheduled Event Current Deadline Proposed Deadline
Discovery Cut-off February 28, 2018 April 30, 2018
Dispositive Motion March 30, 2018 May 29, 2018
Pretrial Order April 30, 2018 June 29, 2018
This Request for an extension of time is not sought for any improper purpose or other purpose of delay. Rather, it is sought by the parties solely for the purpose of allowing sufficient time to finish necessary discovery.
ORDER
