STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT (L.R. 144)

GARLAND E. BURRELL, Jr., Senior District Judge.

Plaintiff FLOSERFIDA GARFIL ("Plaintiff") and Defendant DELL FINANCIAL SERVICES, LLC ("Defendant"), by and through their respective counsel, hereby stipulate and agree as follows:

WHEREAS, on July 22, 2014, Plaintiff filed her Complaint in this action;

WHEREAS, on August 11, 2014, Plaintiff served Defendant with a copy of the Complaint and Summons in a Civil Action;

WHEREAS, pursuant to Federal Rule of Civil Procedure 12(a), Defendant initially needed to file and serve a response to Plaintiff's Complaint on or before September 2, 2014;

WHEREAS, pursuant to stipulation filed on August 22, 2014, the parties extended the time for Defendant's response by 28 days, to and including September 30, 2014, as authorized by Local Rule 144 without Court order;

WHEREAS, pursuant to stipulation and Court order entered on September 24, 2014, the time for Defendant's response was further extended to October 31, 2014;

WHEREAS, the parties are engaged in settlement discussions and wish to continue those discussions before Defendant must prepare and file a response to Plaintiff's Complaint;

WHEREAS, Defendant's counsel Alexander M. Porcaro will be traveling outside the United States from November 19, 2014 through December 7, 2014;

WHEREAS both parties have agreed that good cause exists to extend the time for Defendant to respond to Plaintiff's Complaint to and including December 31, 2014;

NOW, THEREFORE, THE PARTIES HEREBY AGREE AND STIPULATE THAT Defendant shall have to and including December 31, 2014, to move, answer, or otherwise respond to Plaintiff's Complaint.

IT IS SO STIPULATED.

[PROPOSED] ORDER

IT IS SO ORDERED.