STIPULATION AND [PROPOSED] ORDER CONTINUING EXPERT DISCLOSURE AND EXPERT DISCOVERY DEADLINES

JON S. TIGAR, District Judge.

RECITALS

WHEREAS the parties have exchanged written discovery and substantial documents in the case, and otherwise diligently worked together to move the case forward with respect to discovery and the scheduling of depositions;

WHEREAS Plaintiff's deposition (two sessions) was completed on January 10, 2017;

WHEREAS the deposition of Dr. Linda Centore is scheduled to take place on February 24, 2017;

WHEREAS two other witness depositions are currently pending and in the process of being scheduled;

WHEREAS the parties participated in mediation with Hon. Justice Lambden on November 15, 2016;

WHEREAS the current expert disclosure deadline is March 6, 2017;

WHEREAS the current expert discovery cutoff deadline is April 10, 2017;

WHEREAS the parties are still in the process of conducting additional fact discovery including written discovery, document production and witness depositions;

WHEREAS the parties desire to conclude fact discovery before engaging in expert witness discovery;

WHEREAS the parties need additional time in order to meaningfully conduct expert witness discovery;

WHEREAS the parties are still in the process of engaging in settlement discussions and desire to determine whether informal resolution is possible before expending significant time and expense conducting expert witness discovery;

WHEREAS the parties respectfully request that the Court continue the current expert discovery deadlines as outlined by the parties below, or as soon thereafter as the Court is available. Alternatively, the parties request a CMC to further discuss these issues with the Court.

STIPULATION

THEREFORE, IT IS HEREBY STIPULATED THAT the expert disclosure and expert discovery cutoff deadlines are continued as follows:

[PROPOSED] ORDER

According to the parties' stipulation, and good cause appearing, it is hereby ordered that the expert disclosure and expert discovery cutoff deadlines of this matter are hereby continued as follows:

IT IS SO ORDERED.