STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND CONTINUE HEARING ON FOR SANCTIONS TO ALLOW PARTIES TO COMPALETE MOTION FOR SANCTIONS JANUARY 23, 2014

WILLIAM H. ORRICK, District Judge.

Counsel for Defendants and Plaintiff stipulate to the following:

Due to scheduling difficulties of parties, the parties are unable to complete the mediation per the court order or before the current Case Management Conference set for January 14, 2014. The mediation session is scheduled for January 23, 2014 before the Honorable Raul A. Ramirez (Ret.). Accordingly, the parties request that the Case Management Conference presently set for January 14, 2014 be rescheduled to February 25, 2014 or in the alternative, a later date that is convenient for the Court.

In addition, counsel request that the hearing on Defendants' Motion For Sanctions currently set for January 22, 2014, also be rescheduled to February 25, 2014, or in the alternative, a later date that is convenient for the Court following the completion of the mediation session.

All parties respectfully request that the court issue an order continuing the Case Management Conference and Hearing on Motion For Sanctions to February 25, 2014, or, in the alternative, to a later date that is convenient to the Court.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that the Case Management Conference, be continued from January 14, 2014 to_______________________. FURTHER, IT IS HEREBY ORDERED that the Defendants' Motion for Sanctions for Failure to Pay Court Ordered Attorneys' Fees be continued from January 22, 2014 to __________________.