STIPULATION TO CONTINUE DISCOVERY AND HEARING ON DISPOSITIVE MOTIONS DEADLINE AND ORDER GRANTING THE REQUEST TO CONTINUE DISCOVERY AND HEARING ON DISPOSITIVE MOTIONS DEADLINE

MORRISON C. ENGLAND, Jr., Chief District Judge.

Plaintiff ERIC HILL ("Plaintiff" or "Hill") and Defendant THE SYGMA NETWORK, INC. ("Defendant" or "Sygma") by and through their counsel, hereby stipulate as follows:

WHEREAS, Plaintiff filed the Complaint on October 24, 2013. WHEREAS, Defendant removed this matter to this Court on December 20, 3013.

WHEREAS, per this Court's Pretrial Scheduling Order of March 18, 2014, discovery shall be completed by September 19, 2014.

WHEREAS, the parties timely exchanged initial disclosures and engaged in written discovery.

WHEREAS, Defendant has previously noticed Plaintiff's deposition to be held on July 18 and August 12, 2014, but has been unable to commence Plaintiff's deposition due to defense counsel's unanticipated scheduling conflicts.

WHEREAS, the parties have agreed to schedule Plaintiff's deposition for August 28, 2014.

WHEREAS, Defendant intends to serve supplemental disclosures, pursuant to Federal Rule of Civil Procedure 26(e), based upon its identification of additional information subject to disclosure which may not be known to Plaintiff.

WHEREAS, due to scheduling conflicts and trial calendar, Plaintiff's counsel is unable to complete discovery, specifically depositions of key witnesses by discovery cut-off date of September 19, 2014.

WHEREAS, per this Court's Pretrial Scheduling Order, the final pretrial conference is scheduled for May 28, 2015.

WHEREAS, per this Court's Pretrial Scheduling Order, trial is set for July 20, 2015.

WHEREAS, the parties desire to extend the fact discovery deadline from September 19 to November 14, 2014.

WHEREAS, the parties desire to extend the deadline to disclose expert witnesses from November 20 until January 15, 2014.

WHEREAS, the parties desire to extend the deadline to hear dispositive motions from March 19 to April 2, 2015.

WHEREAS, the parties' desired extension for discovery and hearing dispositive motions deadlines will not affect the Court's schedule for the final pretrial conference and trial.

THEREFORE, although Plaintiff desired a slightly greater extension, Plaintiff and Defendant currently stipulate to extend the fact discovery deadline to November 14, 2014.

THEREFORE, Plaintiff and Defendant stipulate to extend the expert witness disclosure deadline to January 15, 2015, with an equivalent extension of all attendant expert discovery deadlines arising thereafter.

THEREFORE, Plaintiff and Defendant stipulate to extend the deadline to hear dispositive motions to April 2, 2015.

ORDER

IT IS SO ORDERED.