STIPULATION AND [PROPOSED] ORDER REGARDING OUTSTANDING DISCOVERY DISPUTES

SUSAN ILLSTON, District Judge.

WHEREAS, fact discovery in this matter closed on Monday, June 17, 2013, and trial is scheduled to begin on November 18, 2013.

WHEREAS, Defendant McKesson Corporation and Plaintiff Commonwealth of Virginia (collectively the "Parties") are in the process of meeting and conferring pursuant Section 2 of this Court's Standing Order regarding certain discovery disputes.

WHEREAS, Section 2 of this Court's Standing Order provides that if litigants cannot resolve discovery disputes informally through the meet and confer process, they shall submit a joint statement to the Court stating the nature and status of their dispute, and further provides that, after considering the joint statement, the Court will advise the parties regarding the need, if any, for more formal briefing or a hearing, pursuant to Civil Local Rule 7-1(b).

WHEREAS, pursuant to Local Rule 37-3, all motions to compel must be filed no more than seven days after the close of discovery, i.e., June 21, 2013.

WHEREAS, the Parties wish to continue their meet and confer discussions and believe that it would be beneficial to establish a July 8, 2013 deadline to submit a joint statement if they are unable to fully resolve the current discovery disputes.

NOW THEREFORE, SUBJECT TO COURT APPROVAL, THE PARTIES STIPULATE that the deadline to comply with the provisions of the Court's Standing Order regarding discovery disputes, including the submission of a joint statement regarding any matters that remain in dispute after conclusion of the meet and confer process, shall be July 8, 2013, without waiver of their right to file a motion to compel thereafter if authorized by the Court.

The PARTIES FURTHER STIPULATE that this Stipulation and Proposed Order shall not be the basis for any Party to seek a continuance of the trial date or any other case deadline.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.