STIPULATION AND [PROPOSED] ORDER CONTINUING DISCOVERY CUTOFF DATE

VINCE CHHABRIA, District Judge.

Whereas, the Court's current Minute Order entered November 18, 2014 sets the close of regular discovery for June 17, 2015 (Docket #18);

Whereas, due to the voluminous electronic documents involved in discovery production as well as the number of witness depositions in this matter (three in Chicago, Illinois, and one in Minneapolis, Minnesota), Plaintiff Ginger Matsumoto-Herrera and Defendant Continental Casualty Company (the "Parties") anticipate that additional time will be required for the completion of the depositions in this matter;

Whereas, the Court's current Minute Order does not expressly set forth a deadline for expert disclosures, supplemental expert disclosures, or the close of expert discovery, and the parties desire to set a fixed expert discovery schedule;

Whereas, the parties have agreed to continue the discovery deadline in this matter for sixteen (16) days until July 3, 2015 to address these matters, to exchange expert disclosures on July 15 and rebuttal expert disclosures on July 30, and that the expert discovery deadline in this matter shall be August 21, 2015, and agree that they can do so without disturbing any other date or deadline in the Court's November 18, 2014 Minute Order. Therefore, the Parties stipulate as follows:

STIPULATION

The Parties, by and through their counsel duly authorized, hereby stipulate to and request that the Court enter an Order continuing the discovery cutoff date until July 3, 2015, to exchange expert disclosures on July 15, 2015 and rebuttal expert disclosures on July 30, 2015 and that the expert discovery deadline in this matter shall be August 21, 2015.

[PROPOSED] ORDER

GOOD CAUSE APPEARING, the Stipulation of the Parties is hereby GRANTED. The November 18, 2014 Minute Order is hereby modified continuing the discovery cutoff date until July 3, 2015, the exchange expert disclosures on July 15, 2015 and rebuttal expert disclosures on July 30, 2015 and that the expert discovery deadline in this matter shall be August 21, 2015.

IT IS SO ORDERED.