STIPULATION TO MODIFY INITIAL PRETRIAL SCHEDULING ORDER; ORDER THEREON

MORRISON C. ENGLAND, JR., Senior District Judge.

1. WHEREAS, Plaintiff filed a Complaint in United States District Court, Eastern District,

2. WHEREAS, on April 15, 2019, Plaintiff filed a First Amended Complaint after Defendants filed a Motion to Dismiss;

2. WHEREAS, pursuant to a Minute Order dated August 5, 2019 issued by Relief Courtroom Deputy G. Michel for District Judge Morrison C. England, Jr., this Court denied Defendants' Motion to Dismiss the First Amended Complaint;

3. WHEREAS, Defendants filed an Answer to the First Amended Complaint and a Counter-Claim alleging new causes of action by new Counter-Claimants. On September 27, 2019, Plaintiff filed an Answer to the Counter-Claim.

4. WHEREAS, the case has not been set for trial and the parties have engaged in written discovery and deposition but have not yet completed said discovery due to the recent filing of the Counter-Claim and addition of new parties.

5. WHEREAS, the parties stipulate to modify the Initial Pretrial Scheduling Order as follows:

a. Discovery shall be completed no later than 365 days after the filing of the First Amended Complaint on April 15, 2019;

b. All counsel shall designate and serve an Expert Witness Disclosure not later than 60 days after the close of discovery and any party may serve a supplemental expert witness discovery within 30 days after the designation of experts;

c. Dispositive Motions shall be filed no later than 180 days after the close of non-expert discovery.

d. The parties shall file a Joint Notice of Trial Readiness not later than 30 days after receiving this Court's ruling on the last filed dispositive motion.

6. WHEREAS, in the interest of justice and in an effort to enhance judicial efficiency and preserve resources and good cause exists to modify the Initial Pretrial Scheduling Order because the Answer to the Counter-Claim was filed September 27, 2019, and the parties require additional time to conduct discovery and designate experts and prepare for trial;

7. WHEREAS, the parties request that this Court issue an Order to modify the Initial Scheduling Order.

IT IS SO STIPULATED.

IT IS SO ORDERED.