STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES IN THE DISCOVERY PLAN AND SCHEDULING ORDER

First Request

GEORGE FOLEY, Jr., Magistrate Judge.

Defendants Corporation of the President of The Church of Jesus Christ of Latter-day Saints ("COP") and Corporation of the Presiding Bishop of The Church of Jesus Christ of Latter-day Saints ("CPB"), through the law firm Carbajal & McNutt LLP, Plaintiffs Krishan Lal, Kuldip Kaur, Kanchan Paul, and Ranjana Paul (collectively, "Plaintiffs"), through the law firm Craig P. Kenny & Associates, Defendant Marina Long, through the law firm Kolesar & Leatham, and Plaintiff / Counter-Defendant Krishan Lal, through the Harper Law Group, hereby stipulate and agree pursuant to LR 26-4 to extend the deadlines in the May 7, 2015 Discovery Plan and Scheduling Order, ECF No. 15.

I. CURRENT DEADLINES.

The following are the deadlines in the current Discovery Plan and Scheduling Order:

II. DISCOVERY CONDUCTED TO DATE.

To date, the parties have disclosed witnesses and documents under Rule 26. CPB has served first sets of interrogatories and requests for production upon Plaintiffs. Defendants are also in the process of obtaining Plaintiffs' medical records from their providers.

III. DESCRIPTION OF THE REMAINING DISCOVERY.

The Parties wish to serve additional written discovery, serve additional subpoenas duces tecum upon nonparties, depose nonparty witnesses, depose the Parties, disclose experts, and depose experts.

IV. REASONS FOR EXTENDING THE DEADLINES.

LR 26-4 states "[applications to extend any date set by the discovery plan . . . must . . . be supported by a showing of good cause for the extension/'"Good cause' exists if, notwithstanding its diligence, a party cannot reasonably comply with the current discovery deadlines.1

This personal injury case arises from an automobile accident. Plaintiffs Krishan Lal and Kuldip Kaur are continuing to receive medical treatment and have been recommended for operations. They are currently deciding whether to undergo the operations. Defendants wish to hold off on conducting independent medical examinations (IMEs) and deposing these plaintiffs until after they undergo any future operations. This will allow the IME experts to examine these plaintiffs in their post-operative conditions, as well as allow Defendants to question these plaintiffs at their depositions about any post-operative complications and care. These IMEs and depositions must be conducted prior to any initial expert disclosures. For these reasons, the parties wish to extend the discovery deadlines by two months.

IV. PROPOSED EXTENDED DEADLINES.

The Parties propose extending the following deadlines by two months:

IT IS SO STIPULATED

IT IS SO ORDERED.