STIPULATION AND [PROPOSED] ORDER CONTINUING HEARING AND BRIEFING SCHEDULE ON MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS NOS. 39-55 AS MODIFIED

ELIZABETH D. LAPORTE, District Judge.

WHEREAS, on October 30, 2012, plaintiff Tina M. Ubaldi ("Plaintiff") filed a Motion To Compel Responses To Requests For Production Of Documents Nos. 39-55 ("Motion");

WHEREAS, the deadline for defendants SLM Corporation, Sallie Mae, Inc. and SLM PC Student Loan Trust 2004-A ("Defendants") to file their Opposition to the Motion is currently November 13, 2012;

WHEREAS, Plaintiff's Reply to the Motion is currently due on November 20, 2012;

WHEREAS, the hearing on the Motion is currently scheduled for December 4, 2012;

WHEREAS, Defendants' counsel will be in arbitration on December 4, 2012 on another matter, and the parties have agreed to continue the hearing on the Motion to Compel and to adjust the briefing schedule accordingly;

WHEREAS, pursuant to Civil Local Rules 6-1(b) and 6-2, the parties may request an order changing a deadline that involves papers required to be filed or lodged with the Court or that would extend deadlines set forth in the Local Rules or Federal Rules; and

WHEREAS, this Stipulation is made in good faith and not for purposes of delay.

IT IS HEREBY STIPULATED by and between the parties, through their respective counsel of record, as follows:

(a) The date by which Defendants must file their Opposition to the Motion is continued from November 13, 2012 to November 20, 2012;

(b) The date by which Plaintiff must file her Reply is continued from November 20, 2012 to December 4, 2012;

(c) The hearing on the Motion is continued from December 4, 2012 to December 18, 2012 at 9:00 a.m. in Courtroom E.

[PROPOSED] ORDER

PURSUANT TO THE STIPULATION, IT IS SO ORDERED AS MODIFIED.