EDWARD M. CHEN, District Judge.
IT IS HEREBY STIPULATED AND AGREED, by and between the parties to this action, through their respective counsel of record, as follows:
WHEREAS the parties are respectfully requesting that the Court continues the deadline for mediation for several months, until after the parties have had sufficient time to conduct discovery and go forward with mediation, as well as to move back the Further Case Management Conference.
WHEREAS currently this matter has a deadline to mediate this case by December 11, 2015. (See ECF 24).
WHEREAS the parties and mediator have agreed on a tentative mediation date of either February 5
WHEREAS the parties need some time for additional key discovery before mediation can go forward, such as the collection of relevant medical records, other documents and to complete the depositions of key parties and witnesses. As such, the parties jointly request the Court set the new mediation deadline to late February of 2016. Our assigned mediator, Mr. Todd Boley, agrees with the timing as set forth herein.
WHEREAS this matter currently has a Further Case Management Conference set with Your Honor for December 17, 2015. The parties also request that the Further Case Management Conference be continued to a date following the mediation.
WHEREAS good cause exists to continue the mediation deadline and the Further Case Management Conference.
The parties attest that concurrence in the filing of these documents has been obtained from each of the other Signatories, which shall serve in lieu of their signatures on the document.
The mediation deadline is hereby continued to
The Further Case Management Conference of December 17, 2015, is hereby continued to