The opinion of the court was delivered by: Oliver W. Wanger United States District Judge
Corrections Corporation of America and CCA of Tennessee, LLC
Assigned to: Hon. Oliver W.Wanger Room 3
STIPULATION AND ORDER TO CONTINUE THE DEADLINE FOR ALL NON-EXPERT DISCOVERY
District Judge: Oliver W. Wanger Magistrate Judge: Jennifer L. Thurston
Action filed: July 24, 2009 Trial Date: August 30, 2011
THE PARTIES TO THE ABOVE-CAPTIONED MATTER, by and through their respective attorneys of record, hereby enter into this stipulation to continue the deadline for all non-expert discovery, based on the following:
WHEREAS, the Court issued a Scheduling Conference Order on February 3, 2010; WHEREAS, on October 1, 2010, the Court issued an Order to Continue the Trial and All Related Dates, which set the deadline to complete all non-expert discovery to February 15, 2011;
WHEREAS, the parties have diligently engaged in discovery and commenced the taking of Plaintiff's deposition;
WHEREAS, however, primarily due to trial calendars of respective counsel for both parties, the parties have had difficulty in completing the depositions and discovery in this case and the parties do not believe that they can do so by the current February 15, 2011 deadline;
WHEREAS, the parties have met and conferred and believe that the deadline for the completion of all non-expert discovery should be continued to March 7, 2011 in order to complete outstanding depositions, and follow up discovery;
THEREFORE, THE PARTIES IN THE ABOVE-ENTITLED ACTION HEREBY STIPULATE and agree, and request that this Court make the following orders:
1. That the Court extends the deadline to complete non-expert discovery from February 15, 2011 to March 7, 2011.
Dated: January 3, 2011 APPELL | HILAIRE | BENARDO LLP By /s/ BARRY APPELL Barry Appell Attorney for Plaintiff Dated: January 3, 2011 GLEASON & FAVAROTE, LLP By /s/ ...