STIPULATION AND ORDER TO EXTEND DISCOVERY CUT-OFF [Local Rule 143] Trial Date: January 13, 2014 P .C. O N l o o r 3
This Stipulation is entered into by and among Plaintiff Equal Employment Opportunity Commission ("EEOC"), Intervenor Anthony Okon ("Intervenor"), and Defendant Maita Chevrolet Geo ("Defendant"), by and through their attorneys of record.
WHEREAS, on May 21, 2012, the Court issued a Pretrial Scheduling Order establishing the deadline for non-expert discovery as March 13, 2013 ,and a trial date of January 13, 2014 (Dkt. No. 21);
WHEREAS, the parties have diligently pursued, but have not yet completed, the exchange of written discovery and the taking of depositions of key witnesses for Plaintiff, Intervenor and Defendant;
WHEREAS, Defendant conducted the first day of Intervenor's deposition; WHEREAS, the parties have scheduled or are in the processing of scheduling at least ten additional depositions and the parties are working cooperatively and diligently to accommodate the calendars of not only the witnesses but of the three counsel as well, which has been difficult;
WHEREAS, there have been no previous modifications to the dates set by the Court's Pretrial Scheduling Order;
WHEREAS, the parties in good faith believe that additional time is necessary in order to complete the depositions of key witnesses, respond to written discovery, and fully explore the possibility of settlement;
WHEREAS, the parties agree that extending the deadline for discovery would serve the interests of judicial economy and not cause any prejudice;
THEREFORE, IT IS HEREBY STIPULATED by and among the parties, through their respective counsel, that the Court modify the deadline set forth in the Pretrial Scheduling Order by approximately thirty (30) days to extend the cut --off for non-expert discovery until April 30, 2013.
We hereby attest that we have on file all holographic signatures corresponding to any signatures indicated by a conformed signature (/s/) within this e-filed document.
Dated: February 14, 2013 By: /s/ Eric C. Bellafronto ERIC C. BELLAFRONTO
LITTLER MENDELSON, P.C. Attorneys for Defendant MAITA CHEVROLET GEO
Dated: February 14, 2013
By: /s/ Cindy O'Hara CINDY
O'HARA U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Attorneys for
Plaintiff U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Dated: February 14,
2013 By: /s/ Alan J.
Reinach ALAN J. REINACH CHURCH STATE COUNCIL Attorneys for Intervenor
GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the parties' stipulation, above, is approved and adopted as the Order of this Court, as follows:
The cut-off for non-expert discovery in the above-captioned matter shall be extended from March ...