STIPULATION AND REQUEST TO MODIFY SCHEDULING ORDER FOR GOOD CAUSE AND [FED. R. CIV. P. 16(b)]

KIMBERLY J. MUELLER, District Judge.

Pursuant to Federal Rule of Civil Procedure Rule 16(b)(4) and Section X of the Status (Pretrial Scheduling) Order issued by United States District Judge Kimberly J. Mueller on January 29, 2019 (the "Scheduling Order"), Plaintiff Glenna Strong ("Plaintiff") and Defendant AT&T Services, Inc. ("Defendant") (collectively, the "Parties"), by and through undersigned counsel, hereby jointly stipulate and move to modify the Scheduling Order for good cause, as follows:

1. Plaintiff brought this action on or about September 13, 2018. Plaintiff filed an Amended Complaint on November 7, 2018.

2. Pursuant to the Scheduling Order, the cut-off for discovery is September 20, 2019. The deadline for the Parties to designate and disclose expert witnesses is September 27, 2019. All expert discovery must be completed by November 18, 2019. The deadline for dispositive motions is December 20, 2019. No trial date has been set in this matter.

3. On November 30, 2018, Defendant filed a Motion to Strike Portions of Plaintiff's Amended Complaint (the "Motion to Strike") and a Request for Judicial Notice in Support of Motion to Strike (the "Request for Judicial Notice"). The Motion to Strike and Request for Judicial Notice were heard on January 11, 2019. The Motion to Strike and the Request for Judicial Notice are currently pending before this Court.

4. Defendant has not yet responded to the Amended Complaint. Defendant intends to respond to the Amended Complaint following the Court's anticipated order(s) on the Motion to Strike and Request for Judicial Notice.

5. The Parties have scheduled a Voluntary Dispute Resolution Program ("VDRP") session with neutral Carolee Kilduff for July 9, 2019, which was the first date available for the neutral and the Parties.

6. The Parties are attempting to resolve this matter before incurring the expense of discovery and have informally agreed to stay discovery in this matter pending the outcome of the scheduled VDRP session on July 9, 2019.

7. The requested modification of deadlines in the Scheduling Order is supported by good cause, will promote judicial economy, and will further the interests of justice because the modification will ensure that the pleadings are settled before this matter moves forward with substantive discovery and will permit the Parties to meaningfully explore whether this matter can be resolved without the need to further incur fees and expenses related to the litigation.

8. In light of the above, the Parties have met and conferred and agreed to approach the Court regarding modifications to the Scheduling Order. The Parties stipulate and propose that the Scheduling Order be modified and that the deadlines in the extended by approximately six months, as follows:

9. This is the first extension requested by the Parties for the deadlines reflected in the Scheduling Order.

10. Pursuant to Civil Local Rule 131(e), counsel for Plaintiff has authorized the submission of this document.

ORDER

The Court, having considered the Parties' Stipulation and Request to Modify Scheduling Order, and good cause appearing therefore, hereby modifies the Scheduling Order as follows:

Dated: June 4, 2019.