STIPULATION, REQUEST TO MODIFY THE SCHEDULING ORDER, AND [PROPOSED] ORDER EXTENDING DISCOVERY DEADLINE AND DEFENDANTS' DEADLINE FOR FILING DISPOSITIVE MOTION Complaint Filed: October 26, 2007 Trial Date: None
A scheduling order may be modified upon a showing of good cause. Fed. R. Civ. P. 16(b). Good cause exists when the deadline cannot be met despite due diligence. Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992).
WHEREAS the Court, in its June 13, 2011 Order, set the discovery deadline for October 3, 2011 and the deadline for Defendants to file and/or re-notice any dispositive motion for October 17, 2011;
WHEREAS the parties have completed three of the six depositions that the Court ordered on June 13 but face scheduling conflicts that will prevent them from scheduling the remaining three depositions on or before the current discovery deadline; THEREFORE, the parties, through their respective counsel of record, hereby agree and STIPULATE that:
1. The discovery deadline shall be extended until November 9, 2011; and
2. The deadline for defendants to file and/or re-notice any dispositive motion be extended until November 23, 2011.
The discovery deadline currently scheduled for October 3, 2011, is hereby continued to November 9, 2011. The deadline for Defendants to file and/or re-notice any dispositive motion currently scheduled for October 17, 2011, is hereby continued to November 23, 2011.
Honorable Gregory G. Hollows
© 1992-2011 VersusLaw ...