[PROPOSED] ORDER (ON CONSENT) RE SETTLEMENT CONFERENCE AND DISCOVERY (AS MODIFIED)

PAUL S. GREWAL, Magistrate Judge.

A telephonic conference having been held June 10, 2014 with the Court with plaintiff Marble Bridge Funding Group ("Marble Bridge") and defendant Euler Hermes American Credit Indemnity Company (now known as Euler Hermes North America Insurance Company) ("Euler"), by their respective attorneys, to discuss the progress of discovery, the current discovery cutoff deadlines being June 26, 2014 and July 24, 2014 (for expert discovery) (Dkt. No. 108), on consent of the parties, it is ORDERED as follows:

The continuing settlement conference presently set for June 25, 2014 is adjourned to a date in August-September 2014 on a date to be set by the Court, the parties to confer as to scheduling and to advise the Court as to their availability in such timeframe.

Any discovery disputes (including as to non-party discovery) shall be presented to the Court as follows: The parties shall meet and confer pursuant to Fed. R. Civ. P. 37(a)(1) and Civil Local Rule 37-1(a); the party seeking relief shall submit up to 5 page letter brief to the Court outlining the dispute; to which the opposing party shall submit up to 5 page letter brief to the Court outlining any opposition within five business days; whereupon the Court will schedule a hearing on shortened time, at which the parties may appear telephonically, pending which the moving party may submit a reply not exceeding 3 pages.

The parties shall meet and confer regarding the scheduling of remaining depositions and as to remaining discovery, with plaintiff to produce its deposition witnesses prior to August 8, 2014 and all outstanding discovery and Rule 30(b)(6) designations shall be provided at least three weeks prior to such depositions.

Any request for an extension of fact discovery deadline is to be submitted to Judge Edward J. Davila, and the undersigned Magistrate Judge recommends such extension to June 18, 2014.