[PROPOSED] STIPULATED ORDER REQUESTING COURT CONTINUE ALL DATES BY AT LEAST (90) NINETY DAYS AND STAYING RELEVANT PROCEEDINGS

GARLAND E. BURRELL, Jr., Senior District Judge.

This Stipulation is entered into by and between Plaintiff Anatoli Romanov ("Plaintiff") and Defendants Westward Hospitality Management LLC and Westmont Hospitality Group, Inc. ("Defendants") (collectively herein "Plaintiff" and "Defendants" are referred to as the "Parties"). The Parties respectfully submit this Stipulation and respectfully request the Court extend all dates by at least (90) ninety days and to stay relevant proceedings to allow the Parties to attempt to resolve the litigation through private mediation.

WHEREAS, Plaintiff filed his complaint on or around June 22, 2012, in California state superior court (the "Action") and shortly thereafter drafted his first set of written discovery in the Action tailored for the state court in which the Action was pending;

WHEREAS, Defendants removed the Action to federal court on or around August 12, 2012, prior to Plaintiff having the opportunity to actually serve the discovery;

WHEREAS, shortly after removal, on or around December 19, 2012, Plaintiff served his edited first set of written discovery tailored for the federal court in which the Action is now pending (the "Discovery"). Plaintiff also drafted and served deposition notices for Defendants on or around January 14, 2013;

WHEREAS, Plaintiff granted Defendants at least two extensions of time in which to respond to the Discovery and received Defendants' original responses and objections to the Discovery on or around February 11, 2013;

WHEREAS, shortly thereafter, on or around February 20, 2013, Plaintiff sent a meet and confer correspondence to Defendants which requested supplemental responses be provided to the Discovery on or before February 26, 2013;

WHEREAS, the Parties agreed to extend Defendants' deadline to respond to the meet and confer correspondence on several occasions to allow the Parties to discuss each's amenability to private mediation (the most recent extension is set to expire on March 20, 2013);

WHEREAS, the Parties have agreed to stay further meeting and conferring and motion work, if necessary, related to the Discovery to allow the Parties to participate in private mediation without incurring further costs prior to the completion of that mediation;

WHEREAS, the following dates are currently calendered in this matter which must be continued and/or stayed to allow the Parties to attempt private mediation:

WHEREAS, the Parties have agreed to attempt to resolve the Action through private mediation if the Court approves at least a ninety (90) day extension of these dates and/or staying relevant proceedings currently pending in the Action;

NOW, THEREFORE, the Parties stipulate and agree as follows:

1) The deadlines set forth in the Court's Order dated November 14, 2012, for moving for class certification and setting the Status (Pretrial Scheduling) Conference be rescheduled as follows:

2) The Court stays all relevant aspects of this litigation, including all discovery, to allow the Parties to mediate this case.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION OF THE PARTIES, IT IS SO ORDERED.