STIPULATION TO EXTEND TIME FOR PLAINTIFF TO FILE OPPOSITION TO MOTION TO DISMISS (Dkt. # 28) (FIRST REQUEST) AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME

JAMES C. MAHAN, District Judge.

Pursuant to Local Rule 6-1, Plaintiff Jason Halpern, by and through his undersigned counsel, and Defendant Gary Tharaldson, by and through his undersigned counsel, hereby submit this stipulation to extend Plaintiff's deadline to oppose Defendant's Motion to Dismiss (Dkt. # 28), which was filed on November 20, 2015.1

The current deadline for Plaintiff to file its Opposition is December 7, 2015. Based on the intervening Thanksgiving holiday and the schedule of Plaintiff's counsel, Plaintiff has requested an extension up to and including December 22, 2015 in order to file its Opposition to Defendant's Motion to Dismiss (Dkt. # 28). No prior extensions have been requested in relation to "this deadline. Defendant stipulates and agrees to this extension up to and including December 22, 2015.

Additionally, based on the intervening Christmas holiday and the schedule of Defendant's counsel, the Parties stipulate and agree that the deadline for Defendant's Reply brief be extended up to and including January 12, 2016.

ORDER

Having considered the foregoing, and good cause appearing,

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the Parties' Stipulation to Extend Time for Plaintiff to File Opposition to Motion to Dismiss (Dkt. # 28) (First Request) is GRANTED.

IT IS SO ORDERED.