MORRISON C. ENGLAND, JR., District Judge.
Plaintiff Mobile Hi-Tech Wheels ("MHT") and Defendants TWM Wholesale, LLC, Tire & Wheel Master Inc., Tire & Wheel Master LLC, USA Wheel & Tire Outlet Inc., USA Wheel & Tire Outlet, Inc., Aslam Property, Inc., HB Commercial, LLC, Nadeem Aslam, and Ammad Hussain (collectively, "Defendants"), by and through their respective counsel, hereby jointly request that the Court extend the discovery deadline to permit discovery to be completed by all Parties.
In support of this stipulated request, the Parties submit the following:
1. The deadline for fact discovery to be completed was February 12, 2019.
2. The Parties have been working in good faith to complete discovery in a timely manner.
3. The Parties have not completed all discovery due to continuing scheduling conflicts.
4. The Parties have pending cross motions for summary judgment that have the potential to simplify discovery and narrow the scope of the case.
WHEREFORE, the Parties respectfully request that the Court extend the discovery deadlines as follows:
1. The deadline for fact discovery to be completed be extended to May 30, 2019.
2. The deadline for the designation of experts be extended to June 30, 2019.
3. The deadline for supplemental list of expert witnesses be extended to July 30, 2019.
4. The deadline to submit the Joint Notice of Trial Readiness (if the parties do not intend to file dispositive motions) be extended to August 30, 2019.
5. The deadline for dispositive motions to be extended to August 30, 2019.
IT IS SO STIPULATED.