JOINT STIPULATED MOTION TO STAY MARCH 12 HEARING ON MOTION FOR PROTECTIVE ORDER PENDING SETTLEMENT DISCUSSIONS AND [PROPOSED] ORDER

(FIRST REQUEST)

PEGGY A. LEEN, Magistrate Judge.

Plaintiff Snap Lock Industries, Inc. ("Snap Lock") and Defendant Swisstrax Corporation ("Swisstrax") (collectively, "Parties"), through their undersigned counsel, hereby respectfully jointly submit this Joint Stipulated Motion To Stay March 12 Hearing On Motion For Protective Order Pending Settlement Discussions, and state as follows:

1. Currently pending before this Court is Snap Lock's Emergency Motion for Protective Order Regarding Subpoenas ("Motion for Protective Order"). See ECF No. 92.

2. A hearing on the Motion for Protective Order is currently scheduled for March 12, 2019. See ECF No. 106.

3. Also currently pending before this Court is Swisstrax's Motion to Compel. See ECF No. 102. The Motion to Compel is fully briefed, but a hearing on the motion has not been scheduled.

4. The deadline for completing expert discovery in this case is April 30, 2019, and the deadline for filing dispositive motions is May 30, 2019. See ECF No. 115. The Parties will take a total of six expert depositions and anticipate that both Parties will file one or more dispositive motions.

5. The Parties have agreed to engage in a settlement conference or mediation within the next 60 days, to be completed by May 6, 2019, in an attempt to resolve this dispute. To allow the parties to dedicate their efforts to the potential settlement of this dispute, and to preserve judicial and party resources in the event that settlement negotiations dispose of the case, the parties hereby jointly request that the Court stay all case deadlines to allow the Parties to conduct a settlement conference or mediation.

6. As a result of this, on March 8, 2019, the Parties filed a Joint Stipulation to Continue Case Deadlines Pending Settlement Discussions. See ECF No. 116. In that filing, the Parties requested that the deadlines for completing expert discovery and for filing dispositive motions be stayed, pending the conclusion of the settlement conference or mediation by or on May 6, 2019.

7. The Parties hereby also respectfully request that the hearing related to the Motion for Protective Order scheduled for March 12, 2019, be vacated, and that it be continued to a date after May 6, 2019, as necessary, if the parties are unable to resolve their dispute.

8. The Parties do not currently have a trial date.

9. Good cause exists for this request. Staying the case deadlines, including the March 12 hearing on Motion for Protective Order, will preserve the resources of both the Court and the parties in the event that the ongoing settlement negotiations dispose of this dispute. The Parties are not seeking the extensions for purposes of undue delay.

ORDER

IT IS ORDERED that the hearing on the Motion for Protective Order (ECF No. 92) currently set for March 12, 2019 is VACATED.