TROY L. NUNLEY, District Judge.
Plaintiff Dale Heizer (hereinafter "Plaintiff") and Defendant John Chiang in his official capacity as the State of California Controller (hereinafter "Defendant Controller"), through their undersigned counsel of record, hereby respectfully request that Defendant Controller be granted until and including June 13, 2014, to respond to Plaintiff's First Amended Complaint.
In support of that request, Plaintiff and Defendant Controller state as follows:
1. The responsive pleading on behalf of Defendant Controller is currently due on April 30, 2014. The requested extension until and including June 13, 2104, will afford Defendant Controller a forty-four day extension of time to respond to the First Amended Complaint.
2. Defendant Controller was not named as a defendant when the Original Complaint was filed.
3. No previous extensions of time to respond to the First Amended Complaint have been requested or granted in this case.
4. The requested extension of time is necessary because Defendant Controller has only recently secured counsel to represent him in this case, Plaintiff's First Amended Complaint contains numerous factual allegations that counsel must investigate in order to prepare a responsive pleading, and Defendant Controller's counsel have numerous litigation commitments that will require their attention in the next forty-four days.
5. The requested extension of time will not require the Court to reschedule any pretrial dates previously scheduled in this case.
The foregoing is hereby stipulated between Plaintiff and Defendant Controller, who respectfully request the Court to grant the extension of time.
Plaintiff Dale Heizer and Defendant State Controller have stipulated to a forty-four day extension of time, up to and including June 13, 2014, for Defendant State Controller to file his response to the First Amended Complaint.