JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

DATED SUSAN ILLSTON, District Judge.

RECITALS

1. On July 11, 2014 the parties are required to file their Joint Case Management Conference Statement. On July 18, 2014 the parties are scheduled to attend the Case Management Conference, which is to be held at 2:30 p.m. in Courtroom 10.

2. Also on July 11, 2014 at 9:00 a.m. the Court is scheduled to hear motions by all defendants, by which they seek to dismiss the Plaintiff's First Amended Complaint, or seek to strike those provisions from the Complaint which apply to them.

3. The parties have stipulated and agreed that it would be beneficial to all of them if the Case Management Conference and its associated Case Management Conference Statement were postponed 30 days from their currently scheduled dates. This will provide them with the opportunity to learn the Court's rulings on the various pending motions before they prepare for the Case Management Conference. The parties seek for the Case Management Conference to be rescheduled to the week of August 18, 2014.

4. Good cause exists for such a postponement. No defendant has yet answered. The pleadings are not yet settled. The current Case Management Conference was scheduled before two defendants, Sky Woodruff and Anita Rimes, ever entered their appearances in this action. After those new defendants did so the Court scheduled all pending motions, including those previously scheduled by the other defendants, to their current date of July 11. The pending motions are potentially dispositive. The parties do not yet know, therefore, how many defendants will remain in the case after the Court rules on the various pending motions. Nor do the parties yet know what issues they will face after the Court rules, what Initial Disclosures they will make, and what discovery will be required. Without such knowledge, the parties are not able to prepare a meaningful discovery schedule, or otherwise address the various topics required within their Joint Case Management Conference Statement.

STIPULATION

1. It is hereby stipulated that the Joint Case Management Conference, currently scheduled for July 18, 2014, at 2:30 p.m. in Courtroom 10, may be postponed, and rescheduled for the first available date on the Court's calendar, during the week of August 18, 2014, at the hour of 2:30 p.m.

2. It is further stipulated that the parties' deadline for submission of their Joint Case Management Conference statement, currently set for July 11, 2014, may be postponed until one week before the rescheduled Case Management Conference date.

[PROPOSED] ORDER

Pursuant to the stipulation of the parties, the Case Management Conference shall be, and is hereby continued to August __, 2014 at 2:30 p.m. in Courtroom 10. The Joint Case Management29 Conference Statement shall be filed one week prior to the conference.