JOINT STIPULATION AND PROPOSED ORDER TO CONTINUE SETTLEMENT CONFERENCE

EDMUND F. BRENNAN, Magistrate Judge.

ALL PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, HEREBY STIPULATE AND REQUEST THIS COURT TO ORDER, THAT the settlement conference currently scheduled before Magistrate Judge Edmund F. Brennan on September 15, 2016 at 10:00 a.m. be continued and rescheduled to Thursday, November 10, 2016 February 16, 2017 at 10:00 a.m.

Good cause exists for this continuance: The parties are presently attempting to complete depositions of the principal parties involved, plaintiff Lawrence Yoakum and out-of-state defendant Michelle Perysian. Michelle Perysian's deposition currently is scheduled for September 29, 2016 and the deposition of plaintiff Lawrence Yoakum is set for September 7, 2016. Furthermore, the depositions of plaintiffs Danielle Yoakum and Shelby Yoakum were taken on September 2, 2016. The parties need additional time to complete their discovery on both liability and damages issues in order for plaintiffs and defendant's principal to be prepared for meaningful settlement discussions. Presently, the discovery cutoff date is October 17, 2016, with expert disclosures due on December 16, 2016. A November date for a settlement conference will allow the parties to exchange critical information on the amounts of special damages incurred as well as critical facts on the liability issues.

The parties will submit confidential settlement-conference statements as directed in the original Scheduling Order to Judge Brennan's chambers on or before Thursday, November 3, 2016 February 9, 2017 (one week before the conference).

SO STIPULATED.

[PROPOSED]ORDER

Pursuant to stipulation, IT IS SO ORDERED. The settlement conference scheduled for Thursday, September 16, 2016 at 10:00 a.m. is continued to Thursday, November 10, 2016 February 16, 2017 at 10:00 a.m. The parties will submit confidential settlement-conference statements to Judge Brennan's chambers on or before Thursday, November 10, 2016 February 9, 2017.