STIPULATED JOINT REQUEST FOR CONTINUANCE OF TRIAL AND RELATED DATES AND ORDER THEREON

ANTHONY W. ISHII, Senior District Judge.

The parties, by and through their counsel, agree and jointly request that this Court enter an order continuing the trial date for not less than six months, and requesting a further scheduling conference to set new dates upon the Court's identification of the new trial date.

RECITALS

WHEREAS, trial in this matter is set for October 20, 2015; and,

WHEREAS, discovery cut-off in this matter is March 9, 2015; and,

WHEREAS, most discovery, particularly Defendant's deposition, was delayed until this new year to allow Defendant to tend to her health and the health of her child; and,

WHEREAS, this discovery was not delayed by dilatory or otherwise improper conduct by either party or their counsel, but was in truth necessitated by the medical needs of a party; and,

WHEREAS, Counsel for both parties agree to a six-month continuance of the matter to allow for a proper effort at discovery; then,

The parties hereby agree to the following:

STIPULATION

1. Trial in this matter is continued until April 26, 2016 or such time thereafter as the Court determines to be proper.

2. Discovery in this matter may continue pending the entry of a new discovery cut-off date.

3. The parties shall meet and confer, and thereafter submit a joint scheduling report to the Court within two calendar weeks of the Court's entry of this stipulated order for the determination of new dates, including discovery and motion practice deadlines.

4. The parties shall either submit to the Court's entry of the joint scheduling report as its order or will otherwise attend a further joint scheduling conference as directed by the Court.

ORDER CONTINUING TRIAL ON STIPULATION OF THE PARTIES

The Court, after considering the stipulation of the parties and the reason therefore does hereby order:

1. Trial in this matter is continued until April 26, 2016.

2. Discovery in this matter may continue pending the entry of a new discovery cut-off date.

3. The parties shall meet and confer, and thereafter submit a joint scheduling report to the Court within two calendar weeks of the Court's entry of this stipulated order for the determination of new dates, including discovery and motion practice deadlines.

4. The parties shall submit to the Court's entry of the joint scheduling report as its order or will otherwise attend a further joint scheduling conference as directed by the Court after submission of that report.

IT IS SO ORDERED.