STIPULATION AND (PROPOSED) ORDER RE APPLICATION FOR EXTENSION OF TIME TO MEET AND CONFER ON PLAINTIFFS' MOTION TO COMPEL

JOSEPH C. SPERO, District Judge.

Lead counsel for Defendants DE'LONGHI AMERICA, INC. and DE'LONGHI S.P.A., Rudolph V. Pino, Jr., hereby respectfully requests an Order extending the time for DE'LONGHI AMERICA, INC. and DE'LONGHI S.P.A. to meet and confer with counsel for the Plaintiffs on the Plaintiffs' Motion To Compel to January 20, 2017 and permission for Thomas E. Healy to attend a meet and confer conference during the morning of January 20, 2017. As grounds for this Stipulation, Rudolph V. Pino, Jr., states the following:

1. By way of an Order dated January 6, 2016, your Honor directed all parties to meet and confer with respect to the Plaintiffs' Motion To Compel on or before January 13, 2017.

2. The parties are scheduled to complete the depositions of eight non-party witnesses in San Francisco, California, during January 16-20, 2017, and Plaintiff SHARON CORNELIUS in Auburn, Washington on January 23, 2017. Thomas E. Healy will be handling these depositions on behalf of our office which is based in White Plains, New York.

3. Mr. Healy has handled the discovery and the majority of the depositions thus far on behalf of our office. He is fully knowledgeable as to all aspects of the proceeding and will be co-counsel at the time of trial. Mr. Healy is authorized to make decisions concerning discovery issues on behalf of the De'Longhi Defendants.

4. I also will be on vacation in Australia from January 13, 2017 through January 28, 2017.

5. Since I will be on vacation and Mr. Healy will be San Francisco during January 16-20, 2017, I would respectfully request an extension of the time for DE'LONGHI AMERICA, INC. and DE'LONGHI S.P.A. to meet and confer with counsel for the Plaintiffs' on the Plaintiffs' Motion To Compel to January 20, 2017 and permission for Mr. Healy to attend a meet and confer conference during the morning of January 20, 2017.

6. We have discussed this application with counsel for the Plaintiffs, Walter A. Haynes, IV, and he has indicated that he is available during the morning of January 20, 2017 and will stipulate to this request under the circumstances.

7. There has been no prior request for an extension of the time to meet and confer with respect to counsel for the Plaintiffs' Motion To Compel.

WHEREFORE Defendants DE'LONGHI AMERICA, INC. and DE'LONGHI S.P.A. hereby respectfully request an Order extending the time for DE'LONGHI AMERICA, INC. and DE'LONGHI S.P.A. to meet and confer with counsel for the Plaintiffs on the Plaintiffs' Motion To Compel to January 20, 2017 and permission for Thomas E. Healy to attend a meet and confer conference during the morning of January 20, 2017.

A proposed Order in the form of an endorsement of this Stipulation, in accordance with USDC-NDCA Local Rule 7-12, is provided below.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED that the time for Defendants DE'LONGHI AMERICA, INC. and DE'LONGHI S.P.A. to meet and confer with counsel for the Plaintiffs on the Plaintiffs' Motion To Compel is extended to January 20, 2017 and Thomas E. Healy is granted permission to attend a meet and confer conference during the morning of January 20, 2017.