Filed: Jun. 03, 2016
Latest Update: Jun. 03, 2016
Summary: JOINT STIPULATION RE: EXTENDING FACT WITNESS DISCOVERY DEADLINE FOR THE TAKING OF AGREED UPON FACT WITNESS DEPOSIT IONS AND EXTENDING EXPERT DISCLOSURE DEADLINES; AND ORDER SHEILA K. OBERTO , Magistrate Judge . Plaintiff G.P.P., Inc. d/b/a Guardian Innovative Solutions ("Plaintiff" or "GIS") and Defendant Guardian Protection Products, Inc. ("Defendant" or "Guardian") (collectively referred to as "the parties") submit the following Joint Stipulation re: Extending the Fact Witness Discovery D
Summary: JOINT STIPULATION RE: EXTENDING FACT WITNESS DISCOVERY DEADLINE FOR THE TAKING OF AGREED UPON FACT WITNESS DEPOSIT IONS AND EXTENDING EXPERT DISCLOSURE DEADLINES; AND ORDER SHEILA K. OBERTO , Magistrate Judge . Plaintiff G.P.P., Inc. d/b/a Guardian Innovative Solutions ("Plaintiff" or "GIS") and Defendant Guardian Protection Products, Inc. ("Defendant" or "Guardian") (collectively referred to as "the parties") submit the following Joint Stipulation re: Extending the Fact Witness Discovery De..
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JOINT STIPULATION RE: EXTENDING FACT WITNESS DISCOVERY DEADLINE FOR THE TAKING OF AGREED UPON FACT WITNESS DEPOSIT IONS AND EXTENDING EXPERT DISCLOSURE DEADLINES; AND ORDER
SHEILA K. OBERTO, Magistrate Judge.
Plaintiff G.P.P., Inc. d/b/a Guardian Innovative Solutions ("Plaintiff" or "GIS") and Defendant Guardian Protection Products, Inc. ("Defendant" or "Guardian") (collectively referred to as "the parties") submit the following Joint Stipulation re: Extending the Fact Witness Discovery Deadline for the purposes of Taking Agreed Upon Fact Witness Depositions and Extending Expert Disclosure Deadlines. The parties have been diligently working to complete fact witness discovery within the May 18, 2016 deadline set by the court in its August 25, 2015 Scheduling Order. However, due to scheduling conflicts and the travel required for all of these depositions as well as the additional time needed to complete document production and review, the parties will be unable to complete all of the agreed upon depositions of party witnesses prior to the fact witness discovery cut-off date. Accordingly, the parties will also be unable to complete expert disclosure prior to the current expert disclosure deadlines. Therefore, the parties have agreed and have stipulated pursuant to Federal Rule of Civil Procedure 29 to extend the time in which to complete these party depositions to June 30, 2016. The following depositions are subject to this Stipulation: (1) Charles Gibson, Sr., (2) Debbie Gibson; (3) Frank Gibson; (4) Christopher Nolan; (5) Christopher Taylor; (6) Darrin Lease; and (7) the second FRCP 30(b)(6) deposition of Defendant Guardian based on the deposition notice served on April 26, 2016.
Further, the parties have agreed and stipulated to extend the time with respect to expert discovery as follows:
• Expert Disclosures: July 1, 2016
• Supplemental Expert Disclosures: July 15, 2016
The close for expert discovery will remain August 15, 2016.
Nothing in this stipulation is intended as a waiver of either party's right to seek further modification of the Court's August 25, 2015 Scheduling Order or to seek any other relief from the Court, including with respect to any discovery disputes between the parties.
IT IS SO STIPULATED AND AGREED TO BY ALL PARTIES.
ORDER
Having reviewed the above stipulation, IT IS HEREBY Order (Doc. 42) be modified as follows:1
1. The deadline for fact discovery is extended to June 30, 2016, for the following Defendant Guardian, based on the deposition notice
2. The expert disclosure deadline is extended to July 1, 2016; and
3. The supplemental expert disclosures deadline is extended to July 15, 2016.
These modifications do not change any other existing scheduling deadlines, including the pretrial conference and trial dates.
IT IS SO ORDERED.
