STIPULATION AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES

MICHAEL J. SENG, Magistrate Judge.

STIPULATION

Plaintiffs Charles Stines and Janet R. Stines and Defendant National Railroad Passenger Corporation ("Amtrak"), by and through their attorneys of record, hereby stipulate to extend the deadlines set by the Court in its Scheduling Order dated October 17, 2013. This stipulation shall not affect the pre-trial conference and trial dates.

Good cause exists for the requested extensions because plaintiffs have not yet provided authorizations for the release of pertinent medical records, which are necessary to obtain prior to taking their depositions. This has required the parties to postpone the depositions and further written discovery. The lack of available medical records has further delayed expert discovery, as the records are required for expert analysis. Moreover, plaintiffs requested and were granted multiple extensions to respond to written discovery, which has likewise delayed the discovery process.

Although the parties have been diligently working to complete discovery, they will require additional time to engage in both expert and non-expert discovery so that meaningful settlement discussions may occur and the parties may adequately prepare their case for trial, if necessary. Accordingly, additional time is needed to receive and review plaintiffs' complete medical files and to subsequently conduct plaintiffs' depositions. The parties do not anticipate filing dispositive motions in this matter, but do request that the dispositive motion filing deadline and hearing date be continued in accordance with the new discovery deadlines so that the parties have adequate time to prepare a motion for summary judgment or adjudication, if necessary, after the close of all discovery.

Based on the foregoing, the parties stipulate to the following continuances:

1. The deadline to complete non-expert discovery in compliance with Rule 26 shall be extended from February 28, 2014 to April 15, 2014.

2. The deadline to serve expert witness disclosures and expert reports in compliance with Rule 26(a)(2)(B) shall be extended from March 14, 2014 to May 2, 2014.

3. The deadline to complete all expert discovery, including depositions of expert witnesses, shall be extended from April 28, 2014 to June 16, 2014.

4. The deadline to file, serve, and notice all non-dispositive motions shall be extended from April 28, 2014 to June 16, 2014.

5. The deadline to file, serve, and notice all dispositive motions shall be extended from May 28, 2014 to June 30, 2014.

ORDER

WHEREAS, good cause exists for the relief requested herein, the Court hereby makes the foregoing Stipulation the Order of this Court.

IT IS SO ORDERED.