Filed: Aug. 06, 2019
Latest Update: Aug. 06, 2019
Summary: STIPULATION AND ORDER TO STAY DISCOVERY MORRISON C. ENGLAND, JR. , District Judge . IT IS HEREBY STIPULATED AND AGREED between Plaintiff BPM Health Group, LLC ("Plaintiff") and Defendant Sutherland Healthcare Solutions, Inc. ("Defendant") (collectively the "Parties"), through their respective counsel, that the discovery deadlines contained within the Initial Pretrial Scheduling Order (ECF No. 2), as modified by the Stipulation and Order, dated January 28, 2019 (ECF No. 18), be stayed for a
Summary: STIPULATION AND ORDER TO STAY DISCOVERY MORRISON C. ENGLAND, JR. , District Judge . IT IS HEREBY STIPULATED AND AGREED between Plaintiff BPM Health Group, LLC ("Plaintiff") and Defendant Sutherland Healthcare Solutions, Inc. ("Defendant") (collectively the "Parties"), through their respective counsel, that the discovery deadlines contained within the Initial Pretrial Scheduling Order (ECF No. 2), as modified by the Stipulation and Order, dated January 28, 2019 (ECF No. 18), be stayed for a p..
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STIPULATION AND ORDER TO STAY DISCOVERY
MORRISON C. ENGLAND, JR., District Judge.
IT IS HEREBY STIPULATED AND AGREED between Plaintiff BPM Health Group, LLC ("Plaintiff") and Defendant Sutherland Healthcare Solutions, Inc. ("Defendant") (collectively the "Parties"), through their respective counsel, that the discovery deadlines contained within the Initial Pretrial Scheduling Order (ECF No. 2), as modified by the Stipulation and Order, dated January 28, 2019 (ECF No. 18), be stayed for a period of twenty one (21) days.
The Parties respectfully submit that, pursuant to Federal Rule of Civil Procedure Rules 16(b) and 26, there is good cause for the requested stay, and respectfully request that the Court enter an Order granting the stay sought herein. The good cause is as follows:
1. The Parties are and have been engaged in settlement negotiations in a good faith attempt to resolve this matter informally.
2. As part of those settlement negotiations, the Parties have exchanged correspondence and participated in multiple telephone discussions in an effort to resolve this matter.
3. The Parties have agreed to refrain from further discovery while exploring the possibility of settlement.
4. Under the Stipulation and Order, dated January 28, 2019 (ECF No. 18), the current deadline for the Parties' completion of the production of documents is August 2, 2019 (the "Document Production Deadline").
5. To enable to the Parties' to continue their negotiations without running afoul of the current Document Production Deadline, the Parties respectfully request a brief twenty one (21) day stay of the Document Production Deadline.
6. NOW, THEREFORE, the Parties jointly request and HEREBY STIPULATE that the Court should enter a stay of the Document Production Deadline for a period of twenty one (21) days.
Dated: August __, 2019 McCORMICK, BARSTOW, SHEPPARD,
WAYTE & CARRUTH LLP
By: _______________________________________
Ryan D. Marshall
Attorneys for Plaintiff BPM Health Group, LLC
Dated: August __, 2019 WOODS OVIATT GILMAN LLP
By: _______________________________________
Brian J. Capitummino*
Attorneys for Defendant Sutherland
Healthcare Solutions, Inc.
*admitted pro hac vice
ORDER
Pursuant to the Stipulation of the Parties (ECF No. 19), and good cause appearing therein, the deadline for the parties' completion of the production of documents, as contained within the Stipulation and Order, dated January 28, 2019 (ECF No. 18), shall be STAYED for a period of twenty-one (21) days.
IT IS SO ORDERED.
