STIPULATION AND [PROPOSED] ORDER REASSIGNING CASE TO ANOTHER MAGISTRATE JUDGE FOR SETTLEMENT CONFERENCE AND CONTINUING SETTLEMENT CONFERENCE DEADLINE, STAY OF PROCEEDINGS, AND CASE MANAGEMENT CONFERENCE

EDWARD M. CHEN, District Judge.

Plaintiff Sheri Lyons ("Lyons") and Defendant Bouchaine Vineyards, Inc. ("Bouchaine"), by and through their respective counsel, respectfully submit this Stipulation, with the accompanying proposed Order, requesting that this case be reassigned from Magistrate Judge Laporte to another Magistrate Judge for an early settlement conference, and requesting that the deadline to complete the settlement conference, the stay of proceedings, and the upcoming Case Management Conference be continued. The parties hereby stipulate and agree as follows:

WHEREAS, Lyons filed the instant putative class action against Bouchaine on November 3, 2014;

WHEREAS, the parties believe in good faith that an early settlement is likely to be reached in this case if the parties have the benefit of the considerable knowledge and experience of one of the Court's Magistrate Judges;

WHEREAS, on February 18, 2015, this Court granted the parties' request for referral to a Magistrate Judge for an early settlement conference, ordered that the conference be completed within 60 days, stayed the case until 30 days after the conference, and reset the Case Management Conference to June 18, 2015;

WHEREAS, on February 20, 2015, this case was referred to Magistrate Judge Elizabeth Laporte for a settlement conference;

WHEREAS, Magistrate Judge Laporte had no dates available for a settlement conference in March or April;

WHEREAS, Magistrate Judge Laporte had only two dates available for a full-day settlement conference in May and only two dates in June;

WHEREAS, the parties had scheduling conflicts on the four available dates in May and June that could not be rescheduled, and Judge Laporte has now given those dates to other parties;

WHEREAS, Magistrate Judge Laporte currently has six dates available for a settlement conference in July, but none of those dates work for both parties and their counsel;

WHEREAS, Lyons does not wish to consider dates for the settlement conference past July;

WHEREAS, Lyons and her lead trial counsel reside out of state and must travel from Minnesota to attend the settlement conference;

WHEREAS, the owners of Bouchaine also reside out of state, have significant business obligations, and must travel from Delaware to attend the settlement conference;

WHEREAS, the parties believe that reassignment of the case to a different Magistrate Judge is necessary given Magistrate Judge LaPorte's very limited availability between April and July;

WHEREAS, the parties further believe that the April 18, 2015 settlement conference deadline, the stay of proceedings, and the June 18, 2015 Case Management Conference should all be continued to allow the parties and the newly assigned magistrate judge sufficient time to schedule and complete the settlement conference.

NOW, THEREFORE, THE PARTIES HEREBY AGREE AND STIPULATE, subject to the Court's approval, that

IT IS SO STIPULATED.

[PROPOSED] ORDER

Based on the stipulation of the parties above and for good cause shown, the above-captioned matter is hereby REASSIGNED from Magistrate Judge Laporte to Magistrate Judge Donna M. Ryu for an early settlement conference. The deadline to complete the settlement conference shall be RESET to August 1, 2015. The Case Management Conference currently set for June 18, 2015 shall be RESET to August 20, 2015 at 10:30 a.m.. The stay of proceedings and the post-stay deadlines set forth in the Court's February 18, 2015 Order shall still apply.

IT IS SO ORDERED.