Honorable Morrison C. England, Jr.
STIPULATION OF COUNSEL TO CONTINUE 1) NON-EXPERT DISCOVERY CUT-OFF AND 2) DISPOSITIVE MOTION HEARING CUT-OFF; ORDER Trial date: February 22, 2010 Time: 9:00 a.m.
By and through their attorneys of record, Plaintiff Tara Farrell ("Plaintiff") and Defendant AT&T Mobility LLC ("AT&T"), hereafter referred to as the "Parties," hereby agree and stipulate as follows:
WHEREAS, Plaintiff filed her Complaint in the above-captioned matter on or about March 13, 2008, and trial is presently set for February 22, 2010;
WHEREAS, the Court entered a Pretrial (Status) Scheduling Order (the "Order") on or about August 25, 2008;
WHEREAS, the Order set the non-expert discovery cut-off date in this action for April 24, 2009;
WHEREAS, the Order established August 24, 2009 as the last day that dispositive motions in this matter may be heard;
WHEREAS, the Parties previously stipulated to continue the non-expert discovery and dispositive motion hearing cut-off dates because they were involved in good-faith settlement discussions;
WHEREAS, this Court entered an Order on April 15, 2009, which continued the non-expert discovery and dispositive motion hearing cut-off dates to May 27, 2009 and September 23, 2009, respectively;
WHEREAS, the Parties have been diligently engaging in good faith settlement negotiations;
WHEREAS, good cause exists to further continue the non-expert discovery cut-off date and dispositive motion hearing cut-off date because the Parties remain engaged in good-faith settlement discussions;
WHEREAS, the Parties have already participated in some discovery, including written discovery, document production, and depositions, but wish to further postpone discovery while settlement discussions are ongoing in an effort to reduce costs incurred;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED
TO by and between the Parties, and by and through their respective attorneys of record, that the non-expert discovery cut-off date is continued to June 24, 2009 and that the dispositive motion hearing cut-off date is continued to October 21, 2009 for the sole purpose of providing the Parties ...