STIPULATION TO CONTINUE DEADLINE TO COMPLETE INITIAL DISCLOSURES; ORDER

HAYWOOD S. GILLIAM, JR., District Judge.

WHEREAS, Plaintiff CLEANFISH, LLC ("Plaintiff") filed its Complaint (Dkt. No. 1) on June 25, 2019 and thereafter served the Complaint;

WHEREAS, on July 19, 2019, the ISF Defendants filed their Motion to Dismiss for Lack of Personal Jurisdiction and Failure to State a Claim (Dkt. No. 26), and the Buena Vista Defendants filed their Answer and Crossclaim (Dkt. Nos. 28, 29);

WHEREAS, on August 2, 2019, Plaintiff filed an Amended Complaint (Dkt. No. 35);

WHEREAS, on August 16, 2019, the ISF Defendants filed their Motion to Dismiss for Lack of Personal Jurisdiction and Failure to State a Claim (Dkt. No. 40) and the Buena Vista Defendants filed their Motion to Dismiss for Failure to State a Claim (Dkt. No. 41). Plaintiff opposed both motions (Docs. 43, 44) and the hearings are presently scheduled for December 12, 2019, at 2:00 p.m.;

WHEREAS, the initial Case Management Conference ("CMC"), previously scheduled for September 24, 2019, at 2:00 p.m., was continued to December 12, 2019 at 2:00 p.m. upon stipulation of the parties and by order of this Court; (Dkt. No. 48);

WHEREAS, pursuant to this Court's order continuing the initial Case Management Conference, initial disclosures are scheduled to be exchanged seven (7) days in advance of the initial Case Management Conference, by December 5, 2019;

WHEREAS, given the threshold jurisdictional and substantive issues to be resolved by the Defendants' pending Rule 12 motions, the parties believe good cause exists to extend the date for exchange of initial disclosures to fourteen (14) days after this court enters orders on Defendants' pending Rule 12 motions, so the parties will have clarity on which claims will proceed;

WHEREAS, this stipulation is not made for any improper purpose and will not prejudice any party;

WHEREAS, this stipulation is not intended to operate as an admission of any factual allegation or legal conclusion and is submitted subject to and without waiver of any rights, defenses, affirmative defenses, or objections, including personal jurisdiction, insufficient process, or insufficient service of process; and,

WHEREAS, the requested modifications will not otherwise impact the schedule for the case.

STIPULATION

NOW, THEREFORE, Plaintiff and Defendants stipulate and agree as follows:

1. Pursuant to Civil L.R. 6-2, and subject to the Court's approval, to extend the date for exchange of initial disclosures, currently scheduled for December 5, 2019, to fourteen (14) days after this court enters orders on Defendants' pending Rule 12 motions.

2. That, by entering this Stipulation, the Parties do not admit any factual allegation or legal conclusion and do not waive any rights, defenses, affirmative defenses, or objections, including personal jurisdiction, insufficient process, or insufficient service of process.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED:

1. The date for the parties to exchange initial disclosures is extended to fourteen (14) days after entry of orders on Defendants' pending Rule 12 motions.