Filed: Jun. 02, 2015
Latest Update: Jun. 02, 2015
Summary: JOINT STIPULATION TO EXTEND DISCOVERY AND TRIAL DEADLINES; ORDER THEREON SHEILA K. OBERTO , Magistrate Judge . Plaintiff United States Equal Employment Opportunity Commission ("EEOC" or "Plaintiff") and Defendants Farmers Insurance Exchange ("Farmers" or "Defendant"), through their respective counsel of record, hereby stipulate pursuant to Rules 16 and 26 of the Federal Rules of Civil Procedure as follows: 1. Good Cause to Extend Discovery Deadlines The parties come before the court t
Summary: JOINT STIPULATION TO EXTEND DISCOVERY AND TRIAL DEADLINES; ORDER THEREON SHEILA K. OBERTO , Magistrate Judge . Plaintiff United States Equal Employment Opportunity Commission ("EEOC" or "Plaintiff") and Defendants Farmers Insurance Exchange ("Farmers" or "Defendant"), through their respective counsel of record, hereby stipulate pursuant to Rules 16 and 26 of the Federal Rules of Civil Procedure as follows: 1. Good Cause to Extend Discovery Deadlines The parties come before the court to..
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JOINT STIPULATION TO EXTEND DISCOVERY AND TRIAL DEADLINES; ORDER THEREON
SHEILA K. OBERTO, Magistrate Judge.
Plaintiff United States Equal Employment Opportunity Commission ("EEOC" or "Plaintiff") and Defendants Farmers Insurance Exchange ("Farmers" or "Defendant"), through their respective counsel of record, hereby stipulate pursuant to Rules 16 and 26 of the Federal Rules of Civil Procedure as follows:
1. Good Cause to Extend Discovery Deadlines
The parties come before the court to seek a second extension of the discovery and trial deadlines. The parties anticipate that this will be the final request for extension of these deadlines. The parties have engaged in good faith efforts to further discovery in this matter and to resolve discovery dispute.
The current extension will extend necessary time for the parties to pursue settlement discussions. While no settlement has been reached, the parties have made progress on this matter, including during the April 23, 2015 Settlement Conference, and are attempting to schedule an in person meeting and/or mediation in June 2015. The extension will permit both sides to focus on these settlement discussions without diverting resources and attention to litigation matters.
An extension is also required as Plaintiff's counsel will be unavailable for most of August 2015 to care for a relative. Due to the above reasons as well as other cases and commitments, it has proven difficult to complete the necessary depositions and written discovery prior to the discovery deadline contained in the original scheduling order. As such, the Parties request that the Court for good cause grant the Parties' second request for an extension of time.
2. Stipulation to Conduct Settlement Conference
The parties stipulate that original Joint Scheduling Order be amended to reflect the following new deadlines:
a. Non expert discovery shall be completed by January 8, 2016;
b. Expert disclosure shall be completed by January 29, 2016;
c. Supplemental expert disclosure shall be completed by February 26, 2016;
d. Expert discovery shall be completed by March 18, 2016;
e. Non dispositive motions shall be submitted by April 1, 2016;
f. Dispositive motion shall be submitted by April 22, 2016;
g. Pretrial conference shall be held on July 19, 2016;
h. Trial shall begin August 30, 2016.
IT IS SO STIPULATED.
ORDER
For good cause shown, the stipulation to extend discovery deadlines is hereby approved and the new deadlines for discovery as set forth in the Scheduling Order shall be amended as follows:
a. Non expert discovery shall be completed by January 8, 2016;
b. Expert disclosure shall be completed by January 29, 2016;
c. Supplemental expert disclosure shall be completed by February 26, 2016;
d. Expert discovery shall be completed by March 18, 2016;
e. Non dispositive motions shall be filed by April 1, 2016;
f. Non dispositive motions shall be heard no later than May 4, 2016;
g. Dispositive motions shall be filed by April 22, 2016;
h. Dispositive motions shall be heard no later than June 6, 2016;
i. Pretrial conference shall be held on July 20, 2016;1 and
j. Trial shall begin August 30, 2016.
IT IS SO ORDERED.
