Filed: Mar. 13, 2018
Latest Update: Mar. 13, 2018
Summary: STIPULATION AND ORDER FOR EXTENSION OF REMAINING DEADLINES [SECOND REQUEST] CAM FERENBACH , Magistrate Judge . Pursuant to Federal Rule of Civil Procedure 29(b) and Local Rules 6-1, 7-1, and LR 26-4, the parties hereby submit the following Stipulation and Order for Extension of Remaining Deadlines (Second Request) to extend the discovery deadlines and all related case management deadlines, as set forth in the Court's Scheduling Order [Doc. 13] and Order granting Stipulation to Extend Discov
Summary: STIPULATION AND ORDER FOR EXTENSION OF REMAINING DEADLINES [SECOND REQUEST] CAM FERENBACH , Magistrate Judge . Pursuant to Federal Rule of Civil Procedure 29(b) and Local Rules 6-1, 7-1, and LR 26-4, the parties hereby submit the following Stipulation and Order for Extension of Remaining Deadlines (Second Request) to extend the discovery deadlines and all related case management deadlines, as set forth in the Court's Scheduling Order [Doc. 13] and Order granting Stipulation to Extend Discove..
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STIPULATION AND ORDER FOR EXTENSION OF REMAINING DEADLINES [SECOND REQUEST]
CAM FERENBACH, Magistrate Judge.
Pursuant to Federal Rule of Civil Procedure 29(b) and Local Rules 6-1, 7-1, and LR 26-4, the parties hereby submit the following Stipulation and Order for Extension of Remaining Deadlines (Second Request) to extend the discovery deadlines and all related case management deadlines, as set forth in the Court's Scheduling Order [Doc. 13] and Order granting Stipulation to Extend Discovery Deadline [Doc. 17], by approximately 90 days.
I. STATUS OF DISCOVERY EFFORTS TO DATE
The parties have conducted the following discovery to date:
• Disclosure statements have been exchanged.
• Defendant served Plaintiffs with Interrogatories and Requests for Production on September 19, 2017.
• Plaintiffs have responded to Interrogatories and Requests for Production on October 23, 2017.
• Defendant issued subpoenas duces tecum to Plaintiffs' medical providers in November, 2017.
• Some medical records have been produced by Plaintiffs' medical providers, but not all.
• Plaintiffs issued Interrogatories, Requests for Production, and Requests for Admission to Defendant on February 6, 2018.
• Defendant's responses to Plaintiffs' Interrogatories, Requests for Production, and Requests for Admission will be filed on March 12, 2018.
• Plaintiffs have taken the depositions of the claim handlers involved in this matter and some 30(b)(6) representatives.
• Expert opinions have been exchanged.
II. DISCOVERY REMAINING
•Pending subpoena responses from remaining medical providers to be received by Defendant.
• Deposition of Plaintiffs.
• Deposition of an additional 30(b)(6) Defendant representative.
• Expert depositions.
• Depositions of additional fact witnesses, as necessary.
• Additional subpoenas and written discovery, as necessary.
III. REASONS FOR REQUESTED EXTENSION
Pursuant to Local Rule 26-4, the parties submit that good cause exists for the extension requested below for the following reasons:
The parties have been diligent in conducting written discovery, issuing subpoenas to collect Plaintiffs' relevant medical information, and beginning the deposition process. However, at this time, the parties have been unable to schedule all of the necessary depositions within the current deadlines. Additionally, without all of the relevant medical records collected, it would be premature for Defendant to depose Plaintiffs. The parties are working together to facilitate mutually acceptable dates for the remaining depositions.
As such, good cause is present to extend the current case deadlines, as evidenced by the discovery efforts listed above. The parties have diligently worked together to move this case forward.
IV. CURRENT DATES AND REQUESTED EXTENSIONS
The parties hereby request an extension of the remaining case deadlines as follows:
1. Discovery Cutoff Date:
Current date: March 18, 2018
Requested Extension: June 18, 2018
2. Dispositive Motions:
Current date: April 17, 2018
Requested Extension: July 16, 2018
3. Pretrial Order:
Current date: May 17, 2018
Requested Extension: August 15, 2018 (unless dispositive motions are filed, in which case the pretrial order shall be filed thirty days after the decision on the dispositive motions or further order from the Court).
4. All other deadlines set forth in the Scheduling Order will remain the same.
The parties have complied with the Scheduling Order and its deadlines thus far. This request is the parties' second request to extend any discovery deadlines, and it is made in good faith.
For the reasons above, the parties submit that good cause exists to extend discovery, dispositive motions, and pretrial order, all in accordance with the accompanying Order.
ORDER
IT IS SO ORDERED.
