STIPULATION AND [PROPOSED] ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE

MARIA-ELENA JAMES, District Judge.

Plaintiff International Brotherhood of Electrical Workers, Local 302 ("Plaintiff") and Defendant Roadway Engineering Works, Inc. ("Defendant") (collectively the "Parties"), by and through their respective attorneys of record, hereby stipulate as follows:

WHEREAS, on January 23, 2014, the Parties notified the Court that they had reached a settlement resolving all claims in this case and were in the process of finalizing settlement agreement language, and accordingly jointly requested a continuance of the initial case management conference and of the deadline to file a Rule 26(f) Report and complete initial disclosures for sixty days to allow the Parties sufficient time to finalize and execute the necessary provisions of the settlement agreement;

WHEREAS, on January 24, 2014, the Court entered an order on the parties' stipulation continuing the deadline to file a Rule 26(f) Report and complete initial disclosures to March 24, 2014, and continuing the initial case management conference to March 27, 2014;

WHEREAS, the Parties have since executed a settlement agreement resolving all claims in this case; and

WHEREAS, the Parties need an additional 14 days to finalize settlement payments under the settlement agreement;

The Parties hereby stipulate and jointly request the following:

1. The deadline to file a Rule 26(f) Report and complete initial disclosures shall be continued from March 24, 2014 to April 14; and

2. The Initial Case Management Conference, currently scheduled for March 27, 2014, shall be continued to April 17, 2014. Respectfully submitted,

[PROPOSED] ORDER

Pursuant to the Parties' stipulation, the deadline to file a Rule 26(f) Report and complete initial disclosures is hereby continued to April 14, 2014, and the Initial Case Management Conference, currently scheduled for March 27, 2014, is hereby continued to April 17, 2014.

IT IS SO ORDERED.