Joint Stipulation and Order to Extend Discovery

(First Request)

GEORGE FOLEY, JR., Magistrate Judge.

Plaintiffs Anna H. Williams (collectively, "Plaintiffs") and Trans Union LLC ("Defendant" and together with Plaintiff as the "Parties") by and through their counsel of record hereby stipulate to modify the Court's Order, ECF No. 16, to extend:

Pursuant to LR 26-4, good cause exists to amend the Scheduling Order. The

Parties have diligently pursued discovery. Plaintiff has propounded written discovery requests and is continuing to meet and confer with Trans Union regarding certain documents withheld. The Parties ran into scheduling conflicts with Trans Union's Rule 30(b)(6) witness and Plaintiff has noticed Trans Union's deposition for April 20, 2018. Trans Union has noticed Plaintiff's deposition for April 3, 2018. Furthermore, the Parties are actively discussing resolution of this case. This request for extension of deadlines is made specifically in this fee-shifting matter since the taking of depositions are a significant expense. The Parties ran into limitations based on the availability of the Parties for deposition and therefore seek to extend the expert disclosures deadlines and the corresponding discovery deadlines.

Pursuant to LR 26-4(a), Plaintiff has propounded written discovery requests upon all defendants, Trans Union has propounded discovery on Plaintiff. Trans Union noticed Plaintiff's depositions and Plaintiff has noticed Trans Union's deposition.

Pursuant to LR 26-4(b), the Parties request additional time to continue to meet and confer about discovery disputes, conduct depositions and disclose experts, as necessary. The Parties specifically agree that no class discovery will be conducted unless and until this Court grants Plaintiff's Motion for Leave to file Second Amended Complaint. ECF No. 42. Should this court grant that motion, the Parties will meet and confer regarding class discovery and file an updated proposed discovery plan and scheduling order relating to class discovery.

Pursuant to LR 26-4(d), the Parties propose the following discovery schedule:

For these reasons, the Parties jointly request that this Court modify the Scheduling Order to provide an additional 60 days to complete discovery, and the in the ordinary course file dispositive motions, and the proposed joint pretrial order as described in the proposed timeline above.

This is the Parties' first request for an extension of these deadlines.

ORDER

IT IS HEREBY ORDERED that the Order, ECF No 16, is modified to extend the discovery deadlines as follows:

IT IS SO ORDERED.