UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE JOINT PRE-TRIAL ORDER

(First Request)

MIRANDA M. DU, District Judge.

Plaintiff, MILLENNIUM DRILLING CO., INC. ("Millennium"), and Third-Party Defendants JONATHAN FELDMAN ("Feldman") and PATRIOT EXPLORATION COMPANY, LLC ("Patriot") (collectively, the "Millennium Parties"), by and through their counsel, hereby move the Court for an Order extending the deadline for the filing of the Pre-Trial Order. The Pre-Trial Order is currently due on February 19, 2016, and the Millennium Parties hereby request that the deadline be extended for an additional 30 days to March 21, 2016.

This request is made due to the shear volume of documents produced in this matter and the complex nature of the claims and defenses involved. Additional time is necessary to allow the parties to work through and determine the undisputed facts, the disputed facts and the disputed issues of law for trial. Further, additional time is necessary to work through and determine the stipulations and objections regarding potential trial exhibits. There is also good cause to extend the deadline due the upcoming Settlement Conference before Magistrate Hoffman. Per the Order Scheduling A Settlement Conference (Dkt. #230), the parties settlement statements are due on March 25. It is anticipated that the settlement statements will contain a significant amount of overlap with the Pre-Trial Order, and the extension will allow the parties to work on both submissions in a more efficient and effective manner.

Counsel for the Millennium Parties has consulted with counsel for the Defendants/Third Party Plaintiffs regarding the need and intention to file this motion, and counsel for Defendants/Third Party Plaintiffs affirm that they had no opposition to the motion. For that reason, this motion has been submitted as an unopposed motion.

Therefore, the Millennium Parties hereby request that the deadline to file the Pre-Trial Order be continued from February 19, 2016 to March 21, 2016.