STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND EXTEND ALL RELATED DEADLINES, AND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT

KANDIS A. WESTMORE, Magistrate Judge.

The parties stipulate to, and jointly request, a 60-day continuance of the Initial Case Management Conference currently set for March 24, 2015 at 1:30 p.m. in Courtroom 4, 3rd Floor of this Court, and a 60-day extension of all related deadlines, and seek the Court's approval for same. The parties further stipulate that, if the Court grants the requested continuance, Defendants' deadline to respond to Plaintiffs' Complaint be extended an additional 30-days from the current deadline of March 13, 2015. Good cause exists for the request to continue the Initial Case Management Conference for the following reasons.

This action arises under the Employee Retirement Income Security Act of 1974 ("ERISA"), as amended by the Multiemployer Pension Plan Amendments Act of 1980 (29 U.S.C §§1001-1461 (1982)), to recover withdrawal liability amounts allegedly owed by defendant Washington Township Central Chevrolet Co., d/b/a Central Collision Center, and DOES 1-20 ("Defendants") to Plaintiffs Automotive Industries Pension Trust Fund and its Trustees ("Plaintiffs"), and to enforce the Trust Fund's request for information under ERISA §4219(a)

On December 19, 2014, the Plaintiffs filed a Complaint in this matter.

On December 22, 2014, the Court entered its Order Setting Initial Case Management Conference and ADR Deadlines (Dkt. #5), setting the Initial Case Management Conference for March 24, 2015.

The Defendants have been served in the action as follows: Washington Township Central Chevrolet dba Central Collision Center was served on January 21, 2015 (Dkt. #8).

On February 6, 2015, the parties stipulated to a 30-day extension to March 13, 2015 for Defendants to respond to the Complaint (Dkt. #9).

The reason for the request is that the Defendants are in the process of reviewing and producing voluminous documents to Plaintiffs that may affect the scope of the action and the prospects for settlement, and it would promote efficiency in the handling of the case to permit the parties to review the documents before discussing early settlement, the scope of the pleadings and issues, making initial disclosures, planning discovery and conferring about the scheduling of the case.

Therefore, the parties respectfully request that the Initial Case Management Conference currently scheduled for March 24, 2015 be continued for 60 days.

No previous requests to change these dates have been submitted. The changes will not affect any other deadline on the Court's calendar.

The parties also stipulate that, if the Court approves the requested continuance, Defendants' time to respond to the Complaint is extended by an additional 30 days, to April 13, 2015.

SO STIPULATED.

ORDER

Pursuant to the foregoing Stipulation, and good cause appearing, the Court hereby continues the Initial Case Management Conference in this action 60 days from its currently scheduled date of March 24, 2015 at 1:30 P.m. in Courtroom 4, 3RD Floor of this Court to May 26, 2015 at 1:30 p.m.. All related deadlines are extended accordingly

IT IS SO ORDERED.