STIPULATED REQUEST AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE AND HEARING DATE ON LEGALSHIELD'S MOTION TO COMPEL ARBITRATION

[LOCAL RULES 6-2 AND 7-12]

SAMUEL CONTI, District Judge.

WHEREAS, on March 20, 2015, Defendant LegalShield filed a Motion to Compel Arbitration Under the Associate Agreement ("Motion to Compel Arbitration") (ECF No. 40). That Motion is currently set for hearing on May 1, 2015 at 10:00 a.m.

WHEREAS, pursuant to the Court's local rules, Plaintiff's opposition to the Motion to Compel Arbitration is due on April 3, 2015 and Defendant's reply on the Motion to Compel Arbitration is due on April 10, 2015. Civil L.R. 7-3 (a) & (c).

WHEREAS, Plaintiff's counsel and counsel for Defendant LegalShield have conferred regarding the briefing schedule and hearing date on the Motion to Compel Arbitration.

WHEREAS, the parties seek a three-week extension of time to respond and reply to the Motion to Compel Arbitration because: (1) the Motion presents complex new fact averments by Defendant that are not part of plaintiff's complaint and (2) the Motion requests relief that involves the interplay between multiple contracts and the Court's previous order denying a motion to compel arbitration in this matter (ECF No. 33). To accommodate the extended briefing schedule, the parties further request that the hearing date be moved from May 1, 2015 at 10:00 a.m. to May 29, 2015 at 10:00 a.m. (a date which Plaintiff's counsel has previously confirmed is an available hearing date for the Court).

WHEREAS, no other dates have been set that would be adversely impacted by this short extension.

Prior Continuances

WHEREAS, on October 16, 2014, Defendant LegalShield filed an Administrative Motion for Relief from Case Management Schedule (ECF No. 19), which the Court granted, moving the initial Case Management Conference ("CMC") to January 30, 2015 and resetting related deadlines accordingly (ECF No. 20).

WHEREAS, on January 9, 2015, the parties submitted a Stipulated Administrative Motion for Relief from Case Management Schedule (ECF No. 28), which the Court granted, moving the initial CMC to February 20, 2015, and continuing the Rule 26 deadlines accordingly (ECF No. 29).

WHEREAS, on February 6, 2015, the parties submitted a Stipulated Administrative Motion for Relief from Case Management Schedule (ECF No. 30), which the Court granted, moving the initial CMC to April 17, 2015, and continuing the Rule 26 deadlines accordingly (ECF No. 31).

WHEREAS, the Court granted the above requests to allow more time to rule on the initial Motion to Compel Arbitration.

Effect on Case Schedule

WHEREAS, the parties' request for a change in the hearing date on the motion to compel and corresponding enlargement of time on the briefing schedule does not require changes to the ADR process or other known deadlines in this case.

PROPOSED ORDER

Pursuant to the stipulation of the parties and and good cause being shown, IT IS ORDERED that:

(1) the hearing on LegalShield's Motion to Compel Arbitration Under the Associate Agreement ("Motion to Compel Arbitration") (ECF No. 40), currently scheduled for May 1, 2015, is continued until May 29, 2015 at 10:00 a.m.;

(2) the deadline for Plaintiff's opposition to the Motion to Compel Arbitration currently scheduled for April 3, 2015, is continued until April 24, 2015; and

(3) the deadline for LegalShield's reply on the Motion to Compel Arbitration currently scheduled for April 10, 2015, is continued until May 8, 2015.

PURSUANT TO STIPULATION, IT IS SO ORDERED.