STIPULATION AND ORDER TO SET DATE FOR CASE MANAGEMENT CONFERENCE

JAMES DONATO, District Judge.

DECLARATION OF NICHOLAS T. NIIRO

1. I am an associate with the law firm, Rogers Joseph O'Donnell, attorneys for Defendant Chevron Capital Corporation ("Chevron Capital"). I have personal knowledge of the facts set forth herein and, if called upon, could and would competently testify thereto.

2. On April 8, 2015, the Court issued an order reassigning this case to Judge Donato and setting the Case Management Conference ("CMC") for July 22, 2015, at 1:30 p.m. Dkt. No. 9.

3. On June 11, 2015, the Clerk issued a notice continuing the CMC to August 12, 2015, at 1:30 p.m. Dkt. No. 18.

4. On July 22, 2015, the Clerk issued a notice continuing the CMC to October 7, 2015, at 1:30 p.m. Dkt. No. 22.

5. Judge Donato's Standing Order for Civil Cases requires lead counsel to be present at the CMC. Standing Order, ¶ 7. Lead counsel for Chevron Capital is unavailable on October 7 and 14, 2015. I have conferred with Plaintiff Hong Jacqueline Nguyen Gardner, Trustee of Avalon Nguyen Gardner Trust UTA Dated 8/17/2010, who has agreed to continue the hearing to October 21, 2015, at 1:30 p.m.

6. This continuance would have a minimal effect on the schedule for the case.

7. Therefore, the parties to this action respectfully request that the Court continue the CMC to October 21, 2015, or such other date that is convenient for the Court.

I declare under the penalty of perjury that the foregoing is true and correct. Executed this 27th day of July 2015 in San Francisco, California.

IT IS HEREBY STIPULATED pursuant to Local Rules 6-1(b) and 6-2(a), by the parties to this action, as follows:

The CMC, currently set for October 7, 2015, shall be set for October 21, 2015, or such other date as ordered by the Court.

ORDER

The Case Management Conference is hereby set for October 21, 2015, at 1:30 p.m.

IT IS SO ORDERED.