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

JON S. TIGAR, District Judge.

RECITALS

WHEREAS the parties have exchanged written discovery and substantial documents in the case, conducted numerous witness depositions, and otherwise diligently worked together to move the case forward;

WHEREAS the current deadline to disclose rebuttal expert witnesses is May 1, 2017;

WHEREAS the current expert discovery cutoff is May 15, 2017;

WHEREAS the parties are in the process of completing substantial expert witness discovery;

WHEREAS both parties anticipate disclosing rebuttal expert witnesses;

WHEREAS both parties anticipate taking multiple expert witness depositions;

WHEREAS the parties have identified an issue impacting the scope of testimony to be provided by expert witnesses relating to the issue of damages and therefore require additional time to meet and confer about the issue so as to reach a possible agreement;

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

WHEREAS the parties are still in active settlement negotiations with Justice Lambden of ADR Services following mediation on November 15, 2016, and would like to continue participating in settlement discussions;

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.

WHEREAS the continuance of the deadlines as proposed below will not impact the August 14, 2017 trial date, or any other deadlines set by this Court.

WHEREAS, alternatively, the parties request a CMC to further discuss these issues with the Court.

STIPULATION

THEREFORE, IT IS HEREBY STIPULATED THAT the expert rebuttal 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 rebuttal and expert discovery cutoff deadlines of this matter are hereby continued as follows:

IT IS SO ORDERED.