The opinion of the court was delivered by: Hon. Samuel Conti
STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES
Plaintiff eForce Global, Inc. ("eForce") and defendant Bank of America, N.A. ("Bank of America"), by and through their respective attorneys, stipulate and agree as follows:
1. This Court has set the discovery cutoff date for this case as May 26, 2010, pursuant to its Status Conference Order, dated August 28, 2009.
2. Both eForce and Bank of America (collectively, the "Parties") have diligently participated in discovery and mediation efforts in this action.
3. The parties participated in mediation in November, 2009, but were unsuccessful in reaching a resolution to the case. Subsequently, eForce obtained new counsel, and the parties have been working to schedule and conduct over 15 depositions, many of them involving out-of-state witnesses. One witness who resides in Hong Kong and must travel to the United States for his deposition has limited availability.
4. The Parties do not seek a delay of the trial date, and agree that these modifications to the dates will serve efficiency and allow the completion of fact and expert discovery. This is the first request to modify the pretrial schedule.
THEREFORE, IT IS HEREBY STIPULATED that:
The deadline to complete lay discovery in this action be extended from May 26, 2010, to June 25, 2010.
The deadline for hearings on dispositive motions in this action be extended from June 11, 2010, to June 25, 2010.
The deadline for both parties' opening expert disclosures and reports in this action be extended from April 26, 2010, to May 21, 2010.
A limited liability partnership formed in the State of Delaware The deadline for both parties' rebuttal expert disclosures and reports in this action be extended from April 26, 2010 to June 18, 2010.
REED SMITH LLP The deadline for completing expert discovery in this action be extended to June 30, 2010.
PURSUANT TO STIPULATION, IT IS ...