The opinion of the court was delivered by: Hon. Jeffrey S. White United States District Judge
STIPULATION TO EXTEND TRIAL DEADLINES, DISCOVERY AND MOTION CUT-OFF AND [PROPOSED] ORDER THEREON
And Related Counterclaims. Stipulation to Extend Trial Deadlines
IT IS HEREBY STIPULATED by the parties hereto, through their respective counsel, pursuant to Civil Local Rule 6-2, that: (1) the current trial date of July 11, 2011 be extended to August 8, 2011;
(2) the current pretrial conference date of June 20, 2011 be extended to July 18, 2011;
(3) the last day to hear dispositive motions be extended from May 13, 2011 to June 17, 2011;
(4) the current expert discovery cut-off of April 22, 2011 be extended to May 23, 2011;
(5) the last day for expert disclosure be extended from March 4, 2011 to April 4, 2011; and
(6) the current non-expert discovery cut-off of March 4, 2011 be extended to April 4, 2011.
All other court scheduled dates and deadlines shall remain the same.
Good cause exists to grant this extension as follows: the parties are working together to resolve this matter. The parties attended mediation on December 9, 2010. They are in the process of working out a settlement and anticipate reaching a mutual resolution shortly. To ensure the parties are not prejudiced by their attempts to settle, and to avoid potentially unneeded litigation, they mutually and in good faith, seek an extension of the remaining deadlines.
Previously, stipulations and orders resulted in the following time modifications: On February 23, 2010, the parties stipulated and the Court ordered to extend the time for plaintiffs to file an amended complaint to March 10, 2010 and for defendant to respond to the complaint or first amended complaint, if applicable, to April 2, 2010. On October 15, 2010, the parties stipulated and the Court ordered to extend the last day for fact discovery from January 12, 2011 to March 4, 2011, and the last day for expert discovery would be extended from March 25, 2011 to April 22, 2011.
The stipulation and proposed order, if issued, would affect the fact and expert discovery cut-offs set by the Court via its scheduling order, dated June 21, 2010, Docket No. 20, in the manner shown in Schedule A attached hereto.
WHEREAS the current trial date in this action is July 11, 2011;
WHEREAS the current pretrial conference is set for ...