Filed: Jan. 06, 2020
Latest Update: Jan. 06, 2020
Summary: STIPULATION AND ORDER EXTENDING DISCOVERY CUT-OFF DATE MORRISON C. ENGLAND, JR. , District Judge . Plaintiff Cheyenne Chrisman ("Plaintiff") and Defendant Target Corporation ("Defendant"), by and through their respective counsel of record, hereby stipulate to extend the pretrial deadlines set forth in the Court's January 2, 2019 Initial Pretrial Scheduling Order [Dkt. 5] by ninety (90) days, as follows: • Close of non-expert discovery: from December 27, 2019 to March 26, 2020 • Expert d
Summary: STIPULATION AND ORDER EXTENDING DISCOVERY CUT-OFF DATE MORRISON C. ENGLAND, JR. , District Judge . Plaintiff Cheyenne Chrisman ("Plaintiff") and Defendant Target Corporation ("Defendant"), by and through their respective counsel of record, hereby stipulate to extend the pretrial deadlines set forth in the Court's January 2, 2019 Initial Pretrial Scheduling Order [Dkt. 5] by ninety (90) days, as follows: • Close of non-expert discovery: from December 27, 2019 to March 26, 2020 • Expert di..
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STIPULATION AND ORDER EXTENDING DISCOVERY CUT-OFF DATE
MORRISON C. ENGLAND, JR., District Judge.
Plaintiff Cheyenne Chrisman ("Plaintiff") and Defendant Target Corporation ("Defendant"), by and through their respective counsel of record, hereby stipulate to extend the pretrial deadlines set forth in the Court's January 2, 2019 Initial Pretrial Scheduling Order [Dkt. 5] by ninety (90) days, as follows:
• Close of non-expert discovery: from December 27, 2019 to March 26, 2020
• Expert disclosures due: February 25, 2020 to May 25, 2020
• Supplemental expert disclosures due: March 26, 2020 to June 24, 2020
• Dispositive motions due: June 24, 2020 to September 22, 2020
Additionally, consistent with the Court's Initial Pretrial Scheduling Order [Dkt. 5], the parties' shall file a Joint Notice of Trial Readiness not later than thirty (30) days after receiving this Court's ruling(s) on the last filed dispositive motion, or if no dispositive motion is filed, not later than thirty (30) days after the close of the designation of supplemental expert witnesses, which falls on July 24, 2020.
Pursuant to Local Rule 144(b), the parties certify that this is the first extension sought with regard to the above-referenced deadlines.
This extension is being sought to allow the parties additional time to conduct discovery to obtain evidence to support Plaintiff's claims and Defendant's defenses to those claims, and to allow the parties to direct time and resources towards resolving the case. The extension requested herein will not prejudice any party. This request is made in good faith and not for the purpose of delay.
IT IS SO STIPULATED.
Respectfully submitted,
DATED: December 10, 2019 OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
By: /s/Shannon R. Clawson
ELIZABETH A. FALCONE
SHANNON R. CLAWSON
Attorneys for Defendant
TARGET CORPORATION
DATED: December 9, 2019 BRYANT WHITTEN, LLP
By: /s/Shelley G. Bryant
SHELLEY G. BRYANT
AMANDA B. WHITTEN
Attorneys for Plaintiff
CHEYENNE CHRISMAN
ATTESTATION
Pursuant to Local Rule 131(e), I attest that concurrence in the filing of this document has been obtained from each of the other signatories.
DATED: December 10, 2019 OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
By: /s/Shannon R. Clawson
ELIZABETH A. FALCONE
SHANNON R. CLAWSON
Attorneys for Defendant
TARGET CORPORATION
ORDER
Having reviewed the Stipulation of the Parties and finding good cause, IT IS HEREBY ORDERED that the deadlines set forth in the Court's Initial Pretrial Scheduling Order [Dkt. 5] be extended as follows:
• Close of non-expert discovery: from December 27, 2019 to March 26, 2020
• Expert disclosures due: February 25, 2020 to May 25, 2020
• Supplemental expert disclosures due: March 26, 2020 to June 24, 2020
• Dispositive motions due: June 24, 2020 to September 22, 2020
Additionally, consistent with the Court's Initial Pretrial Scheduling Order [Dkt. 5], the parties are ordered to file a Joint Notice of Trial Readiness no later than thirty (30) days after receiving the Court's ruling(s) on the last filed dispositive motion, or if no dispositive motion is filed, by July 24, 2020.
IT IS SO ORDERED.