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, 2013.

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, August 12, 2014 and August 28, 2014 but has been unable to commence Plaintiff's deposition due to defense counsel's unanticipated scheduling conflicts.

WHEREAS, the parties are conferring regarding scheduling Plaintiff's deposition.

WHEREAS, the parties previously stipulation to slightly extend the deadline to complete discovery and hear dispositive motions without affecting the trial date, which is set for July 20, 2015 per the Court's Pretrial Scheduling Order.

WHEREAS, Plaintiff's counsel is unable to complete discovery, specifically depositions of key witnesses by the current fact discovery cut-off date of November 14, 2014 due to scheduling conflicts.

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

WHEREAS, the parties desire to extend the fact discovery deadline from November 14, 2014 to February 27, 2015.

WHEREAS, the parties desire to extend the deadline to disclose expert witnesses from January 15, 2015 to March 27, 2015.

WHEREAS, the parties desire to extend the deadline to hear dispositive motions from April 2, 2015 to May 14, 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, Plaintiff and Defendant currently stipulate to extend the fact discovery deadline to February 27, 2015.

THEREFORE, Plaintiff and Defendant stipulate to extend the expert witness disclosure deadline to March 27, 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 May 14, 2015.

IT IS SO STIPULATED.

ORDER

Based on the parties' stipulation, and good cause appearing, the parties' request to extend the existing scheduling deadlines is GRANTED. All dates set in this case are VACATED, and an amended pretrial scheduling order will issue hereafter.

IT IS SO ORDERED.