JOINT STIPULATION AND MOTION TO CONTINUE DISCOVERY CUTOFF; AND ORDER

MORRISON C. ENGLAND, JR., District Judge.

JOINT STIPULATION

Plaintiff PAULA BADELLA and Defendant RASH CURTIS & ASSOCIATES, by and through their respective counsel, hereby stipulate and agree as follows:

RECITALS

WHEREAS, Plaintiff commenced this action by filing her Complaint (ECF No. 1) on August 31, 2018; and

WHEREAS, on August 31, 2018, the court issued an Initial Pretrial Scheduling Order (ECF No. 4) which ordered that discovery is to be completed no later than 365 from the date of initially filing, or August 30, 2019; and

WHEREAS, the parties are currently engaged in ongoing settlement discussions but require additional discovery in order to resolve this matter; and

WHEREAS, the parties have agreed that the deposition of Defendant's Rule 30(b)(6) designee shall be taken on September 6, 2019; and

WHEREAS the parties have agreed that Plaintiff's deposition shall also be taken in September 2019 as well; and

WHEREAS, the parties agree that, in the interests of trying to resolve this matter without further judicial intervention or resources, good cause exists to continue the discovery cutoff date; and

WHEREAS, the parties agree that neither party will be prejudiced by the continuance.

STIPULATION

NOW, THEREFORE, the parties, by and through their respective counsel, hereby stipulate and agree that the discovery cutoff should be extended by sixty (60) days from August 30, 2019 to October 29, 2019.

JOINT MOTION

Plaintiff PAULA BADELLA and Defendant RASH CURTIS & ASSOCIATES hereby jointly move to continue the discovery cutoff date by sixty (60) days from August 30, 2019 to October 29, 2019. The Court's Initial Pretrial Scheduling Order (ECF No. 4), provides for modification of the order upon a showing of good cause. Here, the parties have been engaged in settlement discussions and are attempting to resolve this matter by way of settlement, but additional discovery is required in order to fully assess Defendant's potential liability in this matter. Unfortunately, the parties have been unable to coordinate deposition dates within the time to conduct discovery as set forth in the order. However, the parties have met and conferred through their respective counsel, and they have agreed to take the necessary depositions in September 2019. Accordingly, in order to preserve judicial resources and afford the parties an opportunity to resolve this matter without further judicial intervention, the parties respectfully request the Court modify its Initial Pretrial Scheduling Order to continue the discovery cutoff date to September 29, 2019.

ORDER

IT IS HEREBY ORDERED, for good cause shown, that the discovery cutoff is continued by sixty (60) days from August 30, 2019 to October 29, 2019.

IT IS SO ORDERED.