STIPULATION TO CONTINUE HEARING DATE ON DEFENDANTS' MOTION TO COMPEL FURTHER RESPONSES TO DISCOVERY; [PROPOSED] ORDER

ALLISON CLAIRE, Magistrate Judge.

Plaintiff Michelle Hunter ("Plaintiff") and Defendants Atria Management Company, LLC and Atria Senior Living, Inc. ("Defendants"), through their attorneys of record, (collectively the "Parties"), hereby submit the following Joint Stipulation and [Proposed] Order to continue the hearing on Defendant's Motion to Compel Further Responses to Request for Production and Interrogatories and Documents and for Sanctions in the above-captioned action as follows:

STIPULATION

WHEREAS, the hearing on Defendant's Motion to Compel Further Responses to Request for Production and Interrogatories and Documents and for Sanctions ("Motion") is currently scheduled for February 13, 2019, at 10:00 a.m. in Courtroom 26 of the above-captioned Court;

WHEREAS, the Parties participated in an informal discovery telephone conference with Magistrate Judge Claire on February 4, 2019;

WHEREAS, following the conference, the Court ordered the Parties to agree to a date certain for Plaintiff's outstanding document production and a date for Plaintiff's deposition by 5:00 P.M. on February 5, 2019. The Court's order also reminded the Parties that their joint statement on Defendants' Motion was due by close of business on February 6, 2019, unless the motion is withdrawn or the Parties stipulate to a continuance of the hearing;

WHEREAS, the Parties have complied with the Court's order and agreed to dates certain for Plaintiff's outstanding document production and Plaintiff's deposition;

WHEREAS, the Parties agree to continue the hearing on Defendants' Motion to March 20, 2019, which is a date the Court advised is available;

NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties hereto, through their respective attorneys of record, that the hearing on Defendants' Motion to Compel Further Responses to Request for Production and Interrogatories and Documents and for Sanctions be continued from February 13, 2019 to March 20, 2019, at 10:00 a.m. in Courtroom 26 of the above-captioned Court.

IT IS SO STIPULATED.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS ORDERED THAT:

Defendants' Motion to Compel Further Responses to Request for Production and Interrogatories and Documents and for Sanctions be continued from February 13, 2019 to March 20, 2019, at 10:00 a.m. in Courtroom 26 of the Court.