JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT ESI PROTOCOL (SECOND REQUEST)

CAM FERENBACH, Magistrate Judge.

Pursuant to this Court's Order Granting Defendant's Motion to Extend Time to Submit ESI Protocol [Dkt. No. 32], Defendant STIHL Incorporated, by and through its attorneys of record, Snell & Wilmer L.L.P., and Plaintiff Joshua C. Evans ("Plaintiff"), by and through his attorneys of record, hereby file this joint motion for a 4 day extension of the March 10, 2016 deadline to file an Electronically Stored Information (ESI) protocol. The parties submit this joint motion based on the following:

The parties are presently working diligently to develop and file an ESI protocol. On February 18, 2016, Plaintiff's counsel sent counsel for STIHL Incorporated an initial draft of the ESI protocol. Because of the detailed procedures involved in the ESI protocol, STIHL Incorporated needed additional time to review Plaintiff's initial draft and provide its suggested revisions. On March 7, 2016, STIHL Incorporated's counsel sent Plaintiff's counsel a draft of STIHL Incorporated's ESI protocol for their consideration, proposing that Plaintiff adopt STIHL Incorporated's proposed ESI protocol in lieu of Plaintiff's proposed ESI protocol. On the evening of March 9, 2016, Plaintiff's counsel sent STIHL Incorporated's counsel Plaintiff's requested revisions to STIHL Incorporated's proposed ESI protocol. STIHL Incorporated is currently drafting a counterproposal for Plaintiff's consideration in hopes of resolving the parties' disagreements as to the ESI Protocol without this Court's assistance. In addition, Plaintiff is currently drafting what Plaintiff believes will be a "middle ground" regarding the areas of disagreement in STIHL Incorporated's proposed ESI. To this end, the parties are in the process of scheduling a meet and confer telephone call for March 11, 2016, to hopefully resolve any remaining disagreements with respect to an ESI protocol. In light of the foregoing, STIHL Incorporated requested, and Plaintiff agreed to, a short, 4 day extension of the March 10, 2016 deadline to file an ESI protocol. Therefore, the parties respectfully request an additional 4 days, up to and including March 14, 2016, to finalize and file an ESI protocol.