SECOND STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO AMEND COMPLAINT

JEFFREY S. WHITE, District Judge.

In support of their mutual request to continue Plaintiff's deadline to amend his complaint from September 30, 2015 to October 30, 2015, Plaintiff William Burdt and Defendant Whirlpool Corporation ("Whirlpool") stipulate as follows:

1. On August 5, 2015, the Court entered its Order granting Whirlpool Corporation's motion to dismiss.

2. The Court further granted Plaintiff leave to amend his complaint by August 31, 2015.

3. Thereafter the parties met and conferred regarding the present status of the case and claims and initiated resolution discussions.

4. To facilitate these discussions, the parties stipulated to, and this Court granted, a continuance of Plaintiff's deadline to amend his complaint through September 30, 2015, in order to allow the parties to pursue resolution discussions without the need to incur additional fees and costs addressing an amended pleading or other matters.

5. During this continuance, Plaintiff's counsel has compiled information relevant to his settlement position in order to prepare a formal, written demand to Whirlpool.

6. Plaintiff's counsel provided Whirlpool with Plaintiff's written demand on September 25, 2015, and Whirlpool is now evaluating Plaintiff's demand and supporting points.

7. In order to allow the parties the further time necessary to fully explore their resolution options and possibly reach an early resolution without the need to incur additional fees and costs in the interim they have stipulated to continue the present deadline to amend by 30 days, through and including October 30, 2015;

8. Therefore, if convenient to the Court, the parties stipulate and request that the Court order that Plaintiff's deadline to amend his complaint be continued from September 30, 2015 to October 30, 2015.

IT IS HEREBY ORDERED that Plaintiff's deadline to amend the complaint, scheduled for September 30, 2015, is continued to October 30, 2015.

IT IS SO ORDERED.