Filed: Dec. 28, 2017
Latest Update: Dec. 28, 2017
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (First Request)\ CARL W. HOFFMAN , District Judge . Pursuant to LR 26-4, all parties hereby stipulate to extend the discovery plan and scheduling order deadlines in this action pursuant to LR 26-4. This is the first request for an extension to the discovery plan and scheduling order in this matter. I. INTRODUCTION On September 21, 2017, this Court granted the parties' discovery plan and scheduling order. ECF No. 12. U
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (First Request)\ CARL W. HOFFMAN , District Judge . Pursuant to LR 26-4, all parties hereby stipulate to extend the discovery plan and scheduling order deadlines in this action pursuant to LR 26-4. This is the first request for an extension to the discovery plan and scheduling order in this matter. I. INTRODUCTION On September 21, 2017, this Court granted the parties' discovery plan and scheduling order. ECF No. 12. Un..
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STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (First Request)\
CARL W. HOFFMAN, District Judge.
Pursuant to LR 26-4, all parties hereby stipulate to extend the discovery plan and scheduling order deadlines in this action pursuant to LR 26-4. This is the first request for an extension to the discovery plan and scheduling order in this matter.
I. INTRODUCTION
On September 21, 2017, this Court granted the parties' discovery plan and scheduling order. ECF No. 12. Unfortunately, Defendants' counsel has experienced a substantial unforeseen workload which is based on unexpected court filings. In light of these events, the parties request an additional 60-day extension to the current discovery deadlines.
II. DISCOVERY COMPLETED TO DATE:
Plaintiff:
Initial Disclosures to Defendants October 3, 2017
First Set of Requests for Production of Documents to Defendants December 1, 2017
First Set of Interrogatories to Defendants December 1, 2017
Defendants:
Initial Disclosures to Plaintiff October 3, 2017
III. DISCOVERY YET TO BE COMPLETED:
Plaintiff will notice depositions of employees of Defendants who Plaintiff believes are likely to have discoverable information that Plaintiff may use to support his claims or defenses, unless used solely for impeachment.
Defendant will conduct Plaintiff's deposition, may depose Plaintiff's expert witness (if any), may disclose a rebuttal expert witness, and complete other discovery.
3. PROPOSED REVISED DISCOVERY PLAN:
A. Summary of Proposed Changes
Current Deadline Revised Deadline
Close of Discovery January 31, 2018 April 2, 2018
Interim Status Report December 2, 2017
Disclosure of Expert
Witnesses December 2, 2017 January 31, 2018
Disclosure of Rebuttal
Experts January 2, 2018 March 3, 2018
Dispositive Motions March 2, 2018 May 1, 2018
Pretrial Order April 1, 2018 May 31, 2018
B. Discovery Cut-Off Date: April 2, 2018.
C. Interim Status Report: The interim status report may be filed no later than December 2, 2017, which is not later than sixty (60) days before the discovery deadline.
D. Disclosure of experts and their reports shall occur by January 31, 2018, which is not later than sixty (60) days before the discovery deadline.
E. Disclosure of rebuttal experts and their reports shall occur by March 3, 2018, which is not later than thirty (30) days before the discovery deadline.
F. Dispositive Motions: Dispositive motions may be filed no later than May 1, 2018, which is thirty (30) days from the discovery cut-off date. In the event that the discovery period is extended from the discovery cut-off date set forth in this Stipulation and Order to Extend Discovery Deadlines and Scheduling Order (First Request), the date for filing dispositive motions shall be extended for the same duration, to be no later than thirty (30) days from the subsequent discovery cut-off date.
G. Pretrial Order: The pretrial order shall be filed by May 31, 2018, which is not later than thirty (30) days after the date set for filing dispositive motions. In the event dispositive motions are filed, the date for filing the joint pretrial order shall be suspended until thirty (30) days after the decision of the dispositive motions or until further order of the Court.
H. Additional Extensions of the Discovery Plan and Scheduling Order: The last day for the parties to file their Motion and/or Stipulation to Extend a deadline subject to this Stipulation and Order to Extend Discovery Deadlines and Scheduling Order shall be at least twenty-one (21) days before the expiration of the deadline, and comply fully with LR 26-4.
I. Any deadline not extended in accordance with the Stipulation and Order to Extend Discovery Deadlines and Scheduling Order set forth above shall remain controlled by the Stipulated Discovery Plan and Scheduling Order (ECF No. 11) filed in this matter on September 19, 2017.
IT IS SO ORDERED.
ORDER
IT IS SO ORDERED.
