STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFFS TO FILE RESPONSE TO DEFENDANTS' MOTION FOR PROTECTIVE ORDER REQUESTING STAY OF HIS DEPOSITION AND DISCOVERY RESPONSES PENDING RESOLUTION OF HIS CRIMINAL TRIAL (DOCUMENT 082)

CAM FERENBACH, Magistrate Judge.

VIRGINIA MITSCHKE ("Plaintiff"), by and through her counsel Kaempfer Crowell and Defendants GOSAL TRUCKING, LTD. and SAMIMI SAEED, by and through their counsel ALVERSON, TAYLOR, MORTENSEN & SANDERS, hereby respectfully submit this Stipulation And Order To Extend Time For Plaintiffs To File Response To Defendants' Motion For Protective Order Requesting Stay Of His Deposition And Discovery Responses Pending Resolution Of His Criminal Trial (Document 082) (First Request) (the "Stipulation"). This Stipulation is made in accordance with LR 6-1, LR 6-2, and LR 7-1 of the Local Rules of this Court, This is the first request for an extension of time to file Plaintiffs' Response To Defendants' Motion For Protective Order Requesting Stay Of His Deposition And Discovery Responses Pending Resolution Of His Criminal Trial (Document 082) (Plaintiffs' "Response").

This Stipulation is entered into at the request of counsel for Plaintiff who respectfully represents that counsel has been working diligently and in good faith to meet the deadline for the filing of Plaintiff's Response, however, despite counsel's best efforts, additional time is needed for preparation of the Response.

The basis of this request has been discussed with counsel for Defendants Samimi Saeed and Gosal Trucking, Ltd., who has no objection to the requested extension of four (4) days, up to and including June 12, 2015, within which to file Plaintiff's Response.

This Stipulation is presented in good faith and not for the purpose of delay.

This is Plaintiffs' first request for an extension of time to file Plaintiffs' Response.

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED.