Mohr v. WeatherTechMOTIONN.D. Ill.July 18, 20191 ACTIVE 44630030v3 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Sharesse Mohr, Plaintiff, v. WEATHER TECH, a/k/a MACNEIL AUTOMOTIVE PRODUCTS LIMITED, Defendant. § § § § § § § § § § Case No. 17-cv-04451 Hon. Gary Feinerman Hon. Mag. M. David Weisman UNOPPOSED MOTION TO EXTEND EXPERT DISCOVERY DATES Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), Plaintiff Sharesse Mohr (“Plaintiff”), by and through her undersigned attorneys, moves to extend the time for the Parties to complete their expert discovery to dates after the close of fact discovery. In support of this Motion, Plaintiff states as follows: 1. On March 19, 2019, the Court entered an Order setting the close of fact discovery as May 10, 2019, and set the dates for the Parties’ expert discovery as follows: Plaintiff’s Rule 26(a)(2) expert disclosures due by May 31, 2019; Plaintiff’s expert(s) to be deposed by June 28, 2019; Defendant’s Rule 26(a)(2) expert disclosures due by July 31, 2019; and Defendant’s expert(s) to be deposed by August 30, 2019. [See Dkt. #91] 2. On May 15, 2019, the Court entered an Order granting Plaintiff’s unopposed motion to extend fact discovery to June 28, 2019, and similarly extended the dates for completion of the Parties’ expert discovery. The new dates set were as follows: Plaintiff’s Rule 26(a)(2) expert disclosures due by July 19, 2019; Plaintiff’s expert(s) to be deposed by August 16, 2019; Case: 1:17-cv-04451 Document #: 100 Filed: 07/18/19 Page 1 of 4 PageID #:314 2 ACTIVE 44630030v3 Defendant’s Rule 26(a)(2) expert disclosures due by September 18, 2019; and Defendant’s expert(s) to be deposed by October 18, 2019. [See Dkt. #95] 3. On July 9, 2019, the Court entered an Order granting Plaintiff’s unopposed motion to extend the close of fact discovery from June 28, 2019, to September 6, 2019. [See Dkt. #99] However, the Court did not similarly extend the dates previously set for the Parties to complete their expert discovery. See id. 4. Plaintiff has not yet taken the 30(b)(6) deposition of Defendant WeatherTech, and that deposition will be important testimony for Plaintiff’s expert to consider before finalizing the expert report. For this reason, Plaintiff respectfully requests that the Court extend the dates previously set for the Parties to complete their expert discovery so that Plaintiff is not required to make its expert disclosure until after the close of fact discovery. 5. Counsel for Plaintiff have consulted with counsel for Defendant WeatherTech, who have advised that they do not oppose this Motion. 6. This Motion is not brought for any improper reason, but rather to ensure fundamental fairness in that that Plaintiff’s expert has the benefit of all testimony gathered during fact discovery prior to finalizing the expert report. WHEREFORE, for the reasons set forth above and for such other and further reasons as may appear to the Court at a hearing on this Motion, Plaintiff Sharesse Mohr respectfully requests that this Court extend the deadlines for the Parties to complete their expert discovery to dates after the close of fact discovery. PLAINTIFF SHARESSE MOHR By: /s/ Ruth A. Bahe-Jachna One of Her Attorneys Ruth A. Bahe-Jachna Case: 1:17-cv-04451 Document #: 100 Filed: 07/18/19 Page 2 of 4 PageID #:314 3 ACTIVE 44630030v3 Scott Dorsett GREENBERG TRAURIG, LLP 77 West Wacker Drive, Suite 3100 Chicago, IL 60601 (312) 456-8400 baher@gtlaw.com dorsetts@gtlaw.com Dated: July 18, 2019 Case: 1:17-cv-04451 Document #: 100 Filed: 07/18/19 Page 3 of 4 PageID #:314 4 ACTIVE 44630030v3 CERTIFICATE OF SERVICE I, Ruth A. Bahe-Jachna, an attorney, certify that on July 18, 2019, a true and correct copy of the foregoing UNOPPOSED MOTION TO EXTEND EXPERT DISCOVERY DATES was served on all counsel of record electronically through the Northern District of Illinois CM/ECF electronic filing system. /s/ Ruth A. Bahe-Jachna Ruth A. Bahe-Jachna Case: 1:17-cv-04451 Document #: 100 Filed: 07/18/19 Page 4 of 4 PageID #:314
