JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION DEADLINE AND CASE MANAGEMENT CONFERENCE

JON S. TIGAR, District Judge.

I. INTRODUCTION

Pursuant to Civil Local Rules 6-1, 6-2 and 17-2, the undersigned counsels hereby jointly request an order changing time for the purpose of conserving the time and resources of the Court and the Parties. In particular, the deadline to complete mediation in this matter is currently set for April 15, 2015 and the Case Management Conference ("CMC") is currently set for April 22, at 2:00 p.m. The Parties request that the deadline to complete mediation be continued to April 22, 2015 and the CMC be continued to April 29, 2015, at 2:00 p.m.

II. THE REQUESTED ORDER TO CHANGE TIME IS APPROPRIATE

Pursuant to Local Rule 6-2(a)(1), Parties filing a stipulation requesting an order changing time that would affect the date of an event already fixed by Court order must (1) set forth with particularity the reasons for the requested change, (2) disclose all previous time modifications in the case, whether by stipulation or Court order, and (3) describe the effect that the requested time modification would have on the schedule for the case.

A. Reasons for the Requested Relief

The reason for the requested order is to promote efficiency and to conserve the time and resources of the Court as well as the Parties. The reason for the requested continuance of the deadline to complete mediation, is for the reason that the mediator selected by the Parties, Gig Kyriacou, a highly regarded mediator for complex employment-related disputes, such as in this case, is not available until April 22, 2015, and the parties have scheduled a mediation with him on that date. Additionally, the Court originally scheduled the next CMC for April 15, 2015 as it was originally anticipated that mediation would be completed by then. The Parties believe that for the sake of efficiency and convenience of the Court, the CMC would be more constructive after the mediation has been completed. Therefore, the Parties request the CMC to be continued to April 29, 2015, at 2:00 p.m. to allow the Parties to complete mediation prior to the CMC.

B. Previous Time Modifications

Pursuant to Local Rule 6-2(a)(2), the Parties disclose that the previous time modifications in this case have been: (1) continuing the Initial Case Management Conference from January 28, 2014 to February 12, 2014 due to judicial reassignment [ECF Doc. No. 10]; (2) continuing the Further Case Management Conference from September 10, 2014, to September 17, 2014 upon the Court's own request [ECF Doc. No. 34]; (3) continuing the Further Case Management Conference by one day from September 17, 2014 to September 18, 2014 pursuant to Stipulation and Order [ECF Doc. No. 52]; and (4) continuing the deadline of August 22, 2014 to participate in mediation to 45 days after the last date for putative class members to opt-in to the FLSA collective action pursuant to Ex Parte Application and Order [ECF Doc. No. 51].

C. Effect on Case Schedule

Pursuant to Local Rule 6-2(a)(3), the requested time modification would have minimal or no effect on the case schedule other than fostering efficiency and convenience for the Court and the Parties. No other dates on the case schedule would be affected by the requested modification.

III. STIPULATION

Plaintiff MICHAEL DEATRICK and Defendant SECURITAS SECURITY SERVICES USA, INC., by and through their counsel of record, hereby stipulate to continue the deadline to complete mediation currently set for April 15, 2015 to April 22, 2015, for the reason that the mediator, selected by the Parties, is not available until April 22, 2015, and the parties have scheduled a mediation with him on that date. Also, the Parties hereby stipulate to continue the CMC from April 15, 2015, at 2:00 p.m. to April 29, 2015, at 2:00 p.m., so that the Parties may complete mediation prior to the CMC.

I, Sherry B. Shavit, am the ECF User whose identification and password are being used to file this Stipulation. In compliance with Local Rule 5-1(i)(3), I attest that all other signatories listed, and on whose behalf the filing is submitted, concur in the filing's content and have authorized the filing.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.