JOINT STIPULATION TO EXTEND TIME TO COMPLETE MEDIATION; [PROPOSED] ORDER ON STIPULATION

EDWARD M. CHEN, District Judge.

TO THE HONORABLE COURT:

The parties hereto, Plaintiff JOYCE CLARK ("Plaintiff") and Defendant HUMANA INSURANCE COMPANY ("Humana"), by and through their respective counsel of record, hereby stipulate as follows:

WHEREAS, Plaintiff filed her Complaint on May 18, 2015, and Humana filed its Answer on July 17, 2015.

WHEREAS, the Parties conducted a Case Management Conference on November 17, 2015, and informed the Court that they had agreed to participate in private mediation following the production of necessary medical records.

WHEREAS, following the November 17, 2015 Case Management Conference, the Court issued a Minute Order that referred the case to private mediation, and directed the Parties to complete mediation within 90 days, or by February 15, 2016.

WHEREAS, Plaintiff obtained the medical records and produced them to Humana on or about December 15, 2015, and Humana has been reviewing the medical records.

WHEREAS, the Parties have agreed upon Martin Quinn as mediator and are scheduling the mediation now, but will not be able to complete mediation by February 15, 2016.

WHEREAS, the Parties seek to extend the deadline to complete private mediation by forty-five (45) days, or until March 30, 2016, to permit them sufficient time to conduct a meaningful mediation and attempt to resolve this case.

IT IS HEREBY STIPULATED by and between Plaintiff and Humana through their respective counsel of record that the deadline for the Parties to complete mediation is extended up to March 30, 2016.

IT IS SO STIPULATED

ORDER

Pursuant to stipulation, the Parties are directed to complete mediation by March 30, 2016.

IT IS SO ORDERED. Further CMC is reset from 3/17/16 to 4/21/16 at 10:30 a.m. An updated joint CMC Statement shall be filed by 4/14/16.