STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR PLAINTIFF TO FILE ITS REPLY IN SUPPORT OF ITS MOTION TO COMPEL

SAMUEL CONTI, District Judge.

Pursuant to Northern District of California Civil Local Rules 6-1(b), 6-2 and 7-12, Plaintiff Moon Mountain Farms, LLC ("MMF") and Non-Party Wells Fargo & Company ("Wells Fargo") (collectively the "Parties"), by and through their respective counsel, hereby stipulate to extend MMF's Reply in Support of its Motion to Compel as follows:

WHEREAS, the Parties who sign this Stipulation constitute all of the parties to this proceeding;

WHEREAS, on April 4, 2014, MMF filed its Notice of Motion and Motion to Compel Compliance with Subpoena;

WHEREAS, on May 30, 2014, Wells Fargo filed its Response to MMF's Motion to Compel Compliance with Subpoena;

WHEREAS, currently MMF's Response was due Friday, June 13, 2014, and the Motion is set to be heard on July 11, 2014, at 10:00 a.m.;

WHEREAS, the Parties conferred on June 15th and 16th regarding MMF's request for a brief extension of time to file its Reply in Support of its Motion to Compel;

WHEREAS, the Parties agree to delaying MMF's Reply due to the unexpected death of MMF counsel's near family member;

WHEREAS, the Parties agree that this extension of time will not jeopardize the disposition of the Parties' pending motions or the dates for the close of discovery, trial date and related deadlines of the underlying action, pending in the United States District Court for the District of Arizona (2:13-cv-00349-SRB);

THE PARTIES DO HEREBY AGREE AND STIPULATE to the following:

1. Plaintiff MMF shall have until Friday, June 20, 2014, to file its Reply in Support of its Motion to Compel.

Respectfully submitted,

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.