Action Filed: June 11, 2010
Trial Date: February 5, 2013
STIPULATION TO MODIFY STATUS (PRETRIAL) SCHEDULING ORDER; AND [PROPOSED] ORDER
WHEREAS the parties have been engaged in active discovery in this litigation and are facing substantial costs and time relative to the outstanding discovery matters;
WHEREAS, the parties continue to participate in a productive and extensive mediation, which began on on August 3, 2011, with David Geronemous, Esq. of JAMS in an attempt to resolve the present case;
WHEREAS the parties continue exchanging informal discovery in connection with their attempt to reach a mediated resolution in this case;
WHEREAS, in lieu of just seeking to extend the present discovery schedule so as to permit its completion (at significant time and expense), the parties believe it would be pragmatic and practical to extend the current scheduling order;
WHEREAS, successful mediation of the matter would obviate the burden and expense of additional formal discovery and motion practice:
THEREFORE, IT IS HEREBY STIPULATED AND AGREED that the Court's Status (Pretrial Scheduling) Order, filed September 17, 2010, as modified by Court's orders on November 4, 2010, December 9, 2010, February 18, 2011, March 23, 2011, April 25, 2011, and August 23, 2011 be modified with the Court's consent as follows, with respect to all pre-certification and post-certification dates:
1. The time to complete non-expert, pre-certification discovery shall be extended from November 11, 2011, to March 12, 2012.
2. The pre-certification expert disclosure schedule shall be modified as follows:
a. The time for each party to designate in writing, file with the court, and serve upon all other parties the name, address, and area of expertise of each expert proposed, accompanied by a written report prepared and signed by the expert, shall be extended from November 30, 2011, to March 30, 2012.
b. The time for pre-certification rebuttal expert disclosures and written reports shall be extended from December 28, 2011 to April 30, 2012.
c. The time to complete pre-certification expert discovery shall be extended from January ...