STIPULATION REQUESTING EXTENSION OF CURRENT DEADLINE TO CONDUCT THE PARTIES' RULE 26(F) CONFERENCE AND TO FILE THE JOINT STATUS REPORT

JOHN A. MENDEZ, District Judge.

THIS STIPULATION is hereby entered into by and between Plaintiff German Tugas and Defendant Hill-Rom Company, Inc. ("Hill-Rom") pursuant to Eastern District of California Local Rule 143(a)(1).

RECITALS

WHEREAS, the Court issued an Order on Febreuary 19, 2016 requiring the parties to meet and confer pursuant to Federal Rule of Civil Procedure 26(f) and to file a joint status report by April 18, 2016 (dkt. 12);

WHEREAS, the parties met and conferred and agreed that early mediation may be productive;

WHEREAS, the parties scheduled a mediation with Mark Rudy, a highly respected wage and hour class action mediator;

WHEREAS, the mediation is scheduled to take place on August 16, 2016, which was the mediator's earliest available mediation date;

WHEREAS, the parties agree to update the Court within 30 days after the completion of the August 16, 2016 mediation and, if settlement is not achieved, the parties agree to file a Rule 26(f) Report by September 15, 2016;

WHEREAS, the parties do not seek this continuance for purposes of delay, but, rather, to efficiently and thoroughly manage the case in regards to timelines, substance, and procedure;

NOW, THEREFORE, the parties hereby stipulate to, and request that the Court order, that the parties' deadline to meet and confer pursuant to Federal Rule of Civil Procedure 26(f) and their deadline to file a joint status report shall be extended until 30 days after the scheduled August 16, 2016 mediation, to September 15, 2016.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Having considered the Joint Stipulation submitted by the parties, and for good cause appearing therefore, IT IS SO ORDERED that the parties shall update the court regarding the results of the mediation or meet and confer pursuant to Federal Rule of Civil Procedure 26(f) and file their joint status report by September 15, 2016.