STIPULATION AND [PROPOSED] ORDER TO CONTINUE VDRP SESSION DEADLINE

GARLAND E. BURRELL, Jr., Senior District Judge.

Plaintiffs and State Farm General Insurance Company ("State Farm"), by and through their respective counsel, hereby jointly request an order to continue the Voluntary Dispute Resolution Program ("VDRP") session deadline as follows:

I.

RECITALS

1. Cynthia Larson, Esq. of the law firm of Orrick, Herrington & Sutcliffee, LLP is appointed to conduct the VDRP session in this matter. The deadline to complete the VDRP session is November 19, 2015. The VDRP session is presently scheduled for November 18, 2015 in Sacramento, California.

2. On November 4, 2015, State Farm learned that a conflict developed with the November 18, 2015 session. Counsel for State Farm promptly notified plaintiffs' counsel as well as the office of Ms. Larsen, and offered four new proposed dates for the VDRP session. Ms. Larsen's office responded that day stating that Ms. Larsen has a conflict with two of the proposed dates. On that same day, plaintiffs' counsel informed the office of Ms. Larsen and State Farm's attorneys that they have conflicts with the other dates proposed by State Farm. Plaintiffs' counsel further informed State Farm's counsel and Ms. Larsen's office that the session will be more meaningful once the depositions of two key witnesses are completed. Those depositions are presently scheduled for December 9, 2016. State Farm's counsel does not disagree that the December 9, 2015 depositions will help the parties better understand the case for purposes of conducting a meaningful VDRP session.

3. The parties met and conferred with one another as well as the office of Ms. Larsen regarding alternative dates to complete the VDRP session. Due to the scheduling conflicts between the parties and Ms. Larsen, it was impossible to schedule an alternative date to conduct the VDRP session prior to the deadline of November 19, 2015. Due to other scheduling conflicts, as well as the holidays in November and December, the parties agreed that rescheduling the session for January 2016 would be prudent.

4. The parties are informed that Ms. Larsen is available on January 19, 2016 and January 21, 2016. The parties have agreed to complete the VDRP session on either January 19, 2016 or January 21, 2016. The parties do not anticipate any further requests for continuances for the VDRP session.

II.

REQUEST FOR ORDER TO CONTINUE VDRP COMPLETION DEADLINE

Based on the foregoing recitals, the parties hereby request an order to continue the date to complete the VDRP session until January 29, 2016.

[PROPOSED] ORDER

Pursuant to the parties' stipulation, the deadline to complete VDRP session is January 29, 2016.