STIPULATION AND PROPOSED ORDER STAYING CERTAIN DISCOVERY PENDING FEDERAL DEFENDANTS' MOTION TO DISMISS
WHEREAS, Plaintiffs in this action have noticed the Deposition of the Army Corps of Engineers for March 25, 2009, and the Deposition of Mike Dietl for March 26, 2009 (collectively, the "Depositions");
WHEREAS, on March 2, 2009, Federal Defendants propounded Interrogatories and a Request for Production of Documents on Plaintiffs;
WHEREAS, on March 6, 2009, Federal Defendants filed a Motion To Dismiss Plaintiffs' Fourth Claim For Relief In Part ("Motion");
WHEREAS, staying the Depositions and Plaintiffs' obligation to respond to Interrogatory Nos. 5-8 and Request for Production 1 as it relates to Interrogatory Nos. 5-8 of the Federal Defendants' discovery while the Federal Defendants' Motion is pending would promote judicial economy and not prejudice any party;
NOW, THEREFORE, it is hereby stipulated between Plaintiffs and Federal Defendants, by and through counsel, that, should the Motion be denied:
1. The time for Plaintiffs' responses to Interrogatory Nos. 5-8 and Request for Production No. 1 as it relates to Interrogatory Nos. 5-8 is extended until 15 days after this Court's resolution of Federal Defendants' Motion.
2. The Depositions will take place within 30 days after the Court's resolution of Federal Defendants' Motion.
3. The parties reserve the right to amend the terms of this Stipulation upon a showing of good cause, or seek other appropriate relief from the Court.
The Court having read and considered the foregoing stipulation, and good cause appearing,
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