STIPULATION AND [PROPOSED] ORDER POSTPONING CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES

JEFFREY S. WHITE, District Judge.

IT IS HEREBY STIPULATED AND REQUESTED by and between the parties who have to date appeared in this action, through their counsel of record, Michael D. Singer and Jennifer L. Connor of Cohelan Khoury & Singer and the Law Offices of Shaag Majarian II, attorneys for Plaintiff LEOBARDO LOPEZ ("Plaintiff"); Rod M. Fliegel and Alison S. Hightower of Littler Mendelson, P.C., attorneys for Defendant BEAVEX, INCORPORATED and Robert J. Romero, Edward F. Donohue and David I. Dalby for Defendant LFL Enterprises, LLC, dba Proforma Screening Solutions (collectively "Defendants"), based upon the following recitals:

1. WHEREAS on April 14, 2015 Defendants filed a motion to transfer venue to the Northern District of Georgia set to be heard on the first available date, May 22, 2015 (Doc. 20);

2. WHEREAS this case is currently set for a Case Management Conference on May 8, 2015 — two weeks before the hearing on the motion to transfer venue — and the parties are required to file a Joint Case Management Statement and make initial disclosures pursuant to Rule 26(a)(1)(C) by May 1, 2015, and to meet and confer pursuant to Rule 26(f) by April 17, 2015;

3. WHEREAS, a transfer of venue likely will result in additional or different case management schedules and requirements, and thus a modest delay on these obligations will further efficient and effective case management and thus serve the interests of economy for the Court and all Parties;

STIPULATION

Pursuant to this Court's Standing Order and Civil Rule 16-2(e), so as to promote efficient and effective case management and thus serve the interests of economy for the Court and all Parties, the Parties hereby stipulate, agree and respectfully request:

1. That the Case Management Conference, currently set for May 8, 2015, be continued until ____________________, 2015, or _____ days after this Court's service of an order on Defendant's Motion To Transfer Venue, assuming that motion is denied;

2. The current May 1, 2015 deadline for the parties to file their Joint Case Management Conference Statement is extended until 14 days prior to the new date for this Case Management Conference;

3. That the last day for the Parties to meet and confer pursuant to this Court's Standing Order, Civil Rule 16-3 and Federal Rule of Civil Procedure, Rule 26(f)(1) be extended to one week from the Court's service of an order on Defendant's Motion To Transfer Venue, assuming the motion is denied;

4. The Parties shall then serve their initial disclosures pursuant to Rule 26 within 14 days of their Rule 26(f) conference; and

5. In the event the Court grants Defendant's pending Motion to Transfer Venue, these deadlines will be vacated and will be set by the transferee district.

IT IS SO STIPULATED.

ORDER

PURSUANT TO STIPULATION, THE COURT HEREBY ORDERS:

1. The Case Management Conference, currently set for May 8, 2015 is continued until ____________________, 2015, or _____ days after thisJune 5 Court's service of an order on Defendant's Motion to Transfer Venue, assuming that motion is denied;

2. The current May 1, 2015 deadline for the parties to file their Joint Case Management Conference Statement is extended until 14 days prior to the new date for this Case Management Conference; and

3. That the last day for the Parties to meet and confer pursuant to this Court's Standing Order, Civil Rule 16-3 and Federal Rule of Civil Procedure, Rule 26(f)(1) be extended to one week from the Court's service of an order on Defendant's Motion To Transfer Venue, assuming the motion is denied;

4. The Parties shall then serve their initial disclosures pursuant to Rule 26 within 14 days of their Rule 26(f) conference; and

5. In the event the Court grants Defendant's pending Motion to Transfer Venue, these deadlines will be vacated and will be set by the transferee district.