STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE DEADLINES FOR DISCOVERY CUTOFF AND DISCLOSURE OF FINAL ROUND OF EXPERTS

JEFFREY S. WHITE, District Judge.

Plaintiff MICHAEL DODGE ("Plaintiff") and Defendant FOODMATCH, INC. ("Defendant") by and through their counsel of record herein, hereby stipulate and agree as follows:

WHEREAS, the Court issued a Civil Minute Order on November 16, 2012, ordering the parties to, among other things, complete discovery by April 29, 2013 and disclose their final round of experts by May 14, 2013;

WHEREAS, the parties participated in a mediation on February 14, 2013 before Robert Fries, Esq. and delayed commencement of discovery pending the results of the mediation;

WHEREAS, the parties were unsuccessful in resolving the case at mediation;

WHEREAS, the parties have been diligently attempting to comply with the Court's pretrial order but need additional time to complete discovery, including depositions;

WHEREAS, the parties need additional time to retain and prepare experts prior to disclosure;

WHEREAS, the parties wish to have an opportunity to discuss settlement before retaining and obtaining reports from all experts;

WHEREAS, the parties agree that continuing the current pre-trial deadlines will not prejudice any party in this case;

NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE to extend the following pre-trial deadlines set by the Court on November 16, 2012, by approximately three months as follows:

The Court CONTINUES Jury Selection to January 8, 2014 at 8:00 a.m.) Jury Trial January 13, 2014 at 8:00 a.m.).

IT IS SO ORDERED.