While I understand everyone's "concern" about the final date for motions, I think everyone is overlooking one basic fact - this is Judge Ward's court and he can do whatever he wants (within reason). What I'm getting at is that the final date of record for motions may come and go, but IF JW was receptive to a Motion (i.e., MSJ) from our team to help move us to settlement, JW could amend the "final" date as he wishes, and accept the motion. Thus, the "final" date is a non-issue.
JMHO, and I KNOW nuttin'!
SGE