STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO CONDUCT INITIAL PLANNING MEETING FILE RULE 26(f) REPORT AND CONTINUING THE CASE MANAGEMENT

MARIA-ELENA JAMES, Magistrate Judge.

STIPULATION

This Stipulation is entered into by plaintiff Tony M. Graham ("Plaintiff') and defendants VCA Antech, Inc. (now known as VCA, Inc.) and VCA Animal Hospitals, Inc. ("Defendants") (collectively, "the parties"), by and through their respective counsel of record and pursuant to Northern District of California Local Rule 6-1(a), with reference to the following:

1. WHEREAS, Plaintiff filed this action on May 12, 2014.

2. WHEREAS, Defendants intend to file a motion to transfer venue pursuant to 28 U.S.C. § 1404 ("venue motion").

3. WHEREAS, the parties have met and conferred concerning the subject matter of this Stipulation.

4. WHEREAS, on June 19, 2014, Defendants waived service of the summons and complaint pursuant to the parties' agreement to work together on a mutually agreeable briefing schedule for Defendants' forthcoming venue motion and an extension of the deadline for Defendants to file an answer or otherwise respond to Plaintiff's complaint.

5. WHEREAS, on July 10, 2014, the parties filed a Stipulation regarding the requested briefing schedule on Defendants' motion to transfer venue. Pursuant to the terms of the parties' Stipulation, the deadline for Defendants to file their venue motion shall be August 18, 2014; the deadline for Plaintiff to file his opposition to the venue motion shall be September 15, 2014; and the deadline for Defendants to file their reply in support of their venue motion shall be September 29, 2014.

6. WHEREAS, the Court issued an Order Setting Initial Case Management Conference and ADR Deadlines, which set these dates:

July 24, 2014: Last day for counsel to meet and confer re Rule 26 issues and ADR process selection and to file ADR documents;

August 7, 2014: Last day to file Rule 26(f) Report and Case Management Statement and to complete initial disclosures; and

August 14, 2014: Initial Case Management Conference.

7. WHEREAS, the parties agree that the interests of justice and judicial economy Case Management Conference.

NOW, THEREFORE, the parties hereby stipulate and agree as follows:

1. The deadline for the parties to conduct their initial Rule 26 meet-and-confer and to file documents concerning ADR issues shall be continued from July 24, 2014, until fourteen (14) days after the Court's ruling on Defendants' venue motion.

2. The parties will exchange initial disclosures during the pendency of Defendants' venue motion, and the deadline to exchange initial disclosures shall be continued from August 7, 2014, to September 2, 2014.

3. The deadline for the parties to file their Rule 26(f) report and Case Management Statement shall be continued from August 7, 2014, until twenty-one (21) days after the Court's ruling on Defendants' venue motion.

4. The Case Management Conference should be continued from August 14, 2014, to a date convenient to the Court, but no sooner than twenty-eight (28) days after the Court's ruling on Defendant's venue motion.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.