STIPULATION AND ORDER MODIFYING SCHEDULING ORDER TO EXTEND TIME FOR EXPERT DISCOVERY

JOHN A. MENDEZ, District Judge.

Plaintiffs I.P., Facundo Palacio Diaz, and Micaela Palacio, and Defendants the United States and Banner Health respectfully submit this stipulation and proposed order modifying the scheduling order to allow expert discovery in this case to continue past the current November 5, 2014 discovery cut off. Good cause exists for such modification because the parties have diligently worked to schedule depositions for the 32 experts in this complex medical malpractice case following supplemental reports disclosed on September 5, 2014. Despite these efforts, certain depositions remain unscheduled because dates before November 5, 2014 on which both the expert and the attorneys are available could not be found. Several depositions also remain unscheduled because the experts' opinions are subject to motions to exclude that will be heard on October 29, 2014. The parties therefore respectfully request that the Court modify the scheduling order to allow expert discovery to continue until December 15, 2014.

Thus far, three expert depositions have been taken and 15 are scheduled on or before November 5. The parties propose to schedule the remaining expert depositions (to the degree motion rulings do not render some such depositions unnecessary) during the November 6 through December 15 timeframe. Modifying the scheduling order to allow this will not affect the May 2015 trial date, as the December 15, 2014 proposed cut off is two weeks before dispositive motions are due on December 31, 2014. The proposed extension will render the parties' joint mid-litigation statement due on December 1, 2014.

IT IS SO ORDERED.