JOINT STIPULATION AND [PROPOSED] ORDER RESCHEDULING INITIAL CASE MANAGEMENT CONFERENCE

WILLIAM H. ALSUP, District Judge.

Plaintiff and Counter-Defendant Elise Clougherty and Defendant and Counterclaimant Joseph Lonsdale stipulate to and respectfully ask the Court to reschedule the Initial Case Management Conference that is currently scheduled for April 2, 2015, at 11:00 a.m., to April 30, 2015, at 11:00 a.m. 8:00 A.M.

There is good cause to reschedule the Case Management Conference, due to a scheduling conflict identified by Mr. Lonsdale's counsel, as set forth in accompanying declaration of Orin Snyder in support of this stipulated request.

Despite these scheduling issues, the parties are working diligently and cooperatively to advance this case. On March 23, 2015, the parties conducted a telephonic meet and confer and discussed motions that Ms. Clougherty plans to file; a schedule for future amendments of pleadings; initial disclosures; interrogatories and depositions; and the case schedule. Among other things, the parties agreed to exchange Rule 16 disclosures and continue to meet and confer concerning these issues.

NOW THEREFORE, the parties stipulate and agree, subject to the Court's approval, that:

(i) the Case Management Conference will be moved from April 2, 2015 to April 30, 2015, at 11:00 a.m.

[PROPOSED] ORDER

Pursuant to the stipulated request, IT IS SO ORDERED.

DECLARATION OF ORIN SNYDER IN SUPPORT OF JOINT STIPULATION AND [PROPOSED] ORDER RESCHEDULING INITIAL CASE MANAGEMENT CONFERENCE

I, Orin Snyder, declare as follows:

1. I am an attorney admitted to practice pro hac vice in California and before this Court. I am a partner in the law firm Gibson, Dunn & Crutcher, LLP, counsel of record for Joseph Lonsdale in this matter. I make this declaration based on my own personal knowledge. Pursuant to Civil L.R. 6-2, I submit this declaration in support of the parties' concurrently filed Joint Stipulation and Proposed Order Rescheduling the Initial Case Management Conference.

2. On March 9, 2015, the Court scheduled the Initial Case Management Conference in this matter for April 23, 2015, at 11:00 a.m. (Doc. No. 36).

3. On March 10, 2015, the Court rescheduled the Case Management Conference for April 2, 2015, at 11:00 a.m. on its own motion (Doc. No. 41).

4. Good Friday occurs and Passover begins on April 3, 2015. My co-counsel and I have pre-existing travel and family commitments related to the holidays on April 2, 2015 and therefore am not able to attend the Case Management Conference as currently scheduled.

5. In light of the religious holidays, my co-counsel and I requested that the parties agree to a new date for the Case Management Conference.

6. Counsel for Ms. Clougherty do not oppose the request.

7. In light of a conversation between Mr. Lonsdale's counsel and the Court's clerk, which was communicated to Ms. Clougherty's counsel, it is believed that the earliest date on which the Court and all parties and lead counsel (many of whom are from outside California) are available to attend the Case Management Conference is April 30, 2015 at 11:00 a.m.

8. Despite these scheduling issues, the parties are working diligently and cooperatively to advance this case. On March 23, 2015, the parties conducted a telephonic meet and confer and discussed motions that Ms. Clougherty plans to file; a schedule for future amendments of pleadings; initial disclosures; interrogatories and depositions; and the case schedule. Among other things, the parties agreed to exchange Rule 16 disclosures and continue to meet and confer concerning these issues.

9. Pursuant to Civil L.R. 6-2(a)(2), I have set forth below a list of previous time modifications in this action:

10. The parties do not foresee this time modification having any effect on the schedule for this matter.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed March 25, 2015.