STIPULATION TO EXTEND DEADLINE FOR FILING DEFENDANT FEDERAL INSURANCE COMPANY'S MOTION FOR SUMMARY JUDGMENT [L.R. 6-2(a)]; [PROPOSED] ORDER

HAYWOOD S. GILLIAM, Jr., District Judge.

TO THE HONORABLE COURT, ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

Plaintiff Angelica Jones ("Plaintiff') and Defendant Federal Insurance Company ("Federal"), by and through their respective counsel of record, hereby submit the following Stipulation extending the deadline for Federal to file its Motion for Summary Judgment, or in the alternative, Summary Adjudication.

WHEREAS, Federal's current deadline to file its Motion for Summary Judgment, or in the alternative, Summary Adjudication is April 30, 2015.

WHEREAS, Federal's Motion for Summary Judgment, or in the alternative, Summary Adjudication is currently scheduled to be heard on June 18, 2015 at 2:00p.m. in Courtroom 15.

WHEREAS, pursuant to Northern District of California Local Rule 7-2(a) and based on a hearing date of June 18, 2015, the deadline for Federal to notice, file and serve its Motion for Summary Judgment, or in the alternative, Summary Adjudication is May 14, 2015.

WHEREAS, the mother of Mary E. McPherson, lead counsel for Federal, was hospitalized during the week of April 24, 2015 and will require post-hospital care. Ms. McPherson is her mother's primary caregiver and is responsible for her care.

WHEREAS, on April 24, 2015, Allison O. Chua, Ms. McPherson's associate, conferred by telephone and email correspondence with James J. Matson, undersigned counsel for the Plaintiff, and Mr. Matson agreed to accommodate counsel by stipulating to extend the deadline for filing Federal's Motion for Summary Judgment, or in the alternative, Summary Adjudication.

WHEREAS, there was only one prior request by Federal for an extension of the deadline for filing its Motion for Summary Judgment, or in the alternative, Summary Adjudication, and Federal does not anticipate any other requests for an extension of this deadline.

NOW, THEREFORE, as permitted under Northern District of California Local Rule 6— 2(a), Plaintiff and Federal, through their respective counsel of record, hereby stipulate and agree as follows:

1. Federal's Motion for Summary Judgment, or in the alternative, Summary Adjudication must be filed and served no later than May 14, 2015.

IT IS SO STIPULATED.

[PROPOSED] ORDER

IT IS HEREBY ORDERED that, good cause appearing, as set forth in the Stipulation to Extend Deadline for Filing Defendant Federal Insurance Company's ("Federal") Motion for Summary Judgment as follows:

1. The current deadline for filing Federal's Motion for Summary Judgment is hereby extended to May 14, 2015.

IT IS SO ORDERED.