STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINES REGARDING ADR SELECTION

RICHARD SEEBORG, District Judge.

By and through their respective attorneys of record, Plaintiff and Counterdefendant Nima Shomali and Defendant and Counterclaimant International Business Machines Corporation ("IBM") (collectively, the "parties") stipulate and agree as follows:

WHEREAS, pursuant to the Reassignment Order (Docket No. 11), the ADR compliance deadlines in this action remain unchanged;

WHEREAS, pursuant to the Order Setting Initial Case Management Conference and ADR Deadlines (Docket No. 4) and ADR Local Rule 3, the parties are required to inform the Court via filing whether they have selected an ADR process by no later than August 20, 2015;

WHEREAS, the parties are required to file the ADR Certification Form signed by parties and counsel by no later than August 20, 2015;

WHEREAS, IBM is unable to file the ADR Certification Form by August 20, 2015, due to a pre-scheduled vacation;

WHEREAS, the parties intend to meet and confer regarding the selection of an ADR process during their Rule 26(f) conference, which has not yet occurred; and

WHEREAS, the deadline for parties to confer pursuant to Rule 26(f) is September 10, 2015;

THEREFORE, the parties request that the deadline for IBM to file its ADR Certification Form and for the parties to meet and confer regarding the selection of an ADR process and to inform the Court of their ADR selection be continued from August 20, 2015 to September 10, 2015.

ORDER

IT IS SO ORDERED THAT THE STIPULATION IS APPROVED.

The deadline for IBM to file its ADR Certification Form and for the parties to meet and confer regarding the selection of an ADR process and to inform the Court of their ADR selection is hereby continued to September 10, 2015.