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UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

JENNIFER KASILAG, et at.,

Plaintiffs,

V. Civil No. 11 1-cv-0l083-RMB-KMW

HARTFORD INVESTMENT FTNANCIAL

SERViCES, LLC,

Defendant.

JENNIFER KASILAG, er al,,

Plaintiffs,

v. Civil No. 1: 14-cv-0l 61 1-RMB-KMW

HARTFORD FUNDS MANAGEMENT

COMPANY, LLC,

Defendant.

JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING

EXPERT DISCOVERY SCHEDULE AND RELATED DEADLINES

WHEREAS, pursuant to the Court’s December 3, 2014 Scheduling Order (Dkt. No. 129

in Civil No. 1:l1-cv-01083), Plaintiffs are scheduled to serve their experl reports and disclosures

pursuant to Fed. R. Civ. P. 26(a)(2) no later than February 13, 2015;

WHEREAS, Plaintiffs’ experts expect to offer opinions concerning or based upon the

deposition testimony of a corporate representative of non-party JPMorgan Chase Dank, NA.

(“J?Morgan”);

WHEREAS, Plaintiffs initially noticed the deposition of JPMorgan for November 14,

2014;

5O1393.1

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WHEREAS, between December 2014 and January 2015, JPMorgan has cancelled or

postponed the deposition on three occasions, the most recent occumng on January 28, 2015, due

to weather conditions that prevented JPMorgan’s designee from traveling from Boston to New

York City for the deposition;

WHEREAS, the deposition of JPMorgan dow will take place on february 4, 2015;

Wi-IEREAS, Plaintiffs have proposed a two-week extension of the deadline to serve their

expert reports and disclosures to allow adequate time after the JPMorgan deposition for Plaintiffs

and their experts to obtain a transcript of the deposition, assess JPMorgan’s testimony, and

incorporate any opinions concerning or based upon such testimony into their expert reports and

disclosures; and

WHEREAS, Defendants have consented to the proposed two-week extension, contingent

upon subsequent deadlines being extended accordingly;

NOW, THEREFORE, the parties hereby STIPULATE AND AGREE, by and through

their undersigned counsel and subject to the Court’s approval, as follows:

1. A]l expert reports and disclosures pursuant to fed. R. Civ. P. 26(a)(2) on behalf of

Plaintiffs shall be served upon counsel for Defendants no later than february 27, 2015.

2. Al] expert reports and disclosures pursuant to fed. R. Civ. P. 26(a)(2) on behalf of

Defendants shall be served upon counsel for Plaintiffs no later than April 16, 2015.

3. Plaintiffs’ rebuttal expert reports and disclosures pursuant to Fed. R. Civ. P.

26(a)(2) shall be served upon counsel for Delëndants no later than May 18, 2015,

4. Depositions of proposed expert witnesses shall be concluded by July 3,2015.

5. Dispositive motions shall be filed with the Clerk of the Court no later than June 5,

2015.

1501393.1

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Dated; January —,20] 5

By: /s/ Robert L. Lakind

Robert L. Lakind

SZAfERMAN, LAKIND,

BLUMSThIN & BLADER, PC.

101 Grovers Mill Road, Suite 200

Lawrenceville, NJ 08648

Tel: (609) 275-0400

F ax: (609) 275-451 1

Attorneysfor Plaintiffs

ED

llespectfuIlv—submitted.

By

Anthony Sylvst

SHERMAN, WELLS, SYLVESTER

& STAMELMAN, LLP

210 Park Ave., 2’ floor

Florham Park, NJ 07932

Tel: (973) 302-9700

fax: (973) 845-2546

Attorneysfor Defendants

aren M. Williams

Jnited States Magistrate Judge

1501393 1

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