JOINT STIPULATION TO EXTEND DEADLINES IN SCHEDULING ORDER PER LOCAL RULES IA 6-1, IA 6-2, 7-1, AND 26-4

THIRD REQUEST

GEORGE FOLEY, JR., Magistrate Judge.

STIPULATION AND [PROPOSED] ORDER

Pursuant to Local Rules IA 6-1, IA 6-2, 7-1, and 26-4, Plaintiff Mary Kaye Welch and Defendants My Left Foot Children's Therapy, LLC ("My Left Foot"), Jon Gottlieb, and Ann Marie Gottlieb ("Defendants") (collectively, the "Parties"), by and through their respective counsel of record, stipulate and agree to extend the deadlines set forth in the Scheduling Order (ECF No. 124). This is the Parties' third request to modify the deadlines in the Scheduling Order. The first request, filed on August 14, 2017 (ECF No. 112), was granted (ECF No. 113), as was the second request, filed on November 3, 2017. (ECF Nos. 123, 124.)

I. STATEMENT OF COMPLETED DISCOVERY

Initial Disclosures

The parties exchanged initial disclosures in June 2014.

Fact Discovery

Fact discovery closed on December 27, 2017.

II. STATEMENT OF DISCOVERY TO BE COMPLETED

Expert discovery remains to be completed. Plaintiffs' expert disclosure deadline is currently set for February 28, 2018, and Defendants' expert disclosure deadline is currently set for March 29, 2018. Plaintiffs must disclose any rebuttal experts by May 7, 2018. Expert discovery is currently scheduled to be completed by June 6, 2018.

III. THE REASONS FOR THE REQUESTED EXTENSION

The parties have agreed to jointly request referral to a judicial settlement conference. To avoid unnecessarily incurring significant costs associated with expert discovery, the parties have also agreed to jointly request a brief extension of the remaining deadlines in the Scheduling Order (ECF No. 124) pending the outcome of the settlement conference.

IV. REVISED PROPOSED DISCOVERY PLAN

The Parties respectfully request that the Court refer the Parties to the Magistrate Judge and stay all expert deadlines pending completion of the settlement conference. Following the completion of settlement conference and if the Parties are unable to resolve the matter, the Parties will propose deadlines for expert designations, reports, and rebuttals that flow from the date of the settlement conference and that are consistent with the timeline that has been previously been approved by the Court. In the interim, the Parties will continue to brief the summary judgment motion filed by Relator and will finish the outstanding fact depositions of Rebecca Bush and Meghan Gebhart.

This request is made in good faith and is designed to promote judicial economy and the efficient use of resources. The Parties welcome the opportunity to participate in a conference call with the Court to the extent the Court believes one to be necessary.

ORDER

IT IS SO ORDERED.