STIPULATION TO EXTEND DEADLINE FOR: DISPOSITIVE MOTIONS, PRE-TRIALCONFERENCE, AND TRIAL DATE

JOHN A. MENDEZ, District Judge.

Pursuant to the Parties' agreement of May 1, 2016, and for the reasons described below, as well as an effort to resolve the case through alternative dispute resolution, the Parties' hereby agree to continue the deadlines set forth for Dispositive Motions, the Pre-Trial Conference and Trial as described below.

On April 11, 2016, the Parties stipulated to submit to the Court's Voluntary Dispute Resolution Program. Because Defendants' counsel and Defendant were both out of the country for the next three weeks, the stipulation was not filed until May 1, 2016.

Plaintiff intends to file a Motion for Summary Adjudication, however both Parties agree that a pending summary judgment or adjudication motion would be a detriment to resolution discussions. Given the stipulation for to submit to the Voluntary Dispute Resolution Program, and the foregoing facts, the Parties have agreed to continue the deadlines set forth for Dispositive Motions, the Pre-Trial Conference and Trial as follows: (1) Dispositive Motions Deadline, currently set for May 3, 2016 will be extended to June 21, 2016, and the Dispositive Motions hearings, currently set for May 31, 2016 will be extended to July 19, 2016 at 1:30 p.m.; (2) the Pre-Trial Conference, currently set for July 1, 2016 at 11:00 a.m. will be extended to August 26, 2016 at 11:00 a.m.; and JURY TRIAL currently set for August 1, 2016 at 9:00 a.m. will be extend to September 26, 2016 at 9:00 a.m. in Courtroom 6 before Judge John A. Mendez.

The Parties respectfully request the Court enter an order that current deadlines listed above be extended as agreed to by the Parties.

WHERAS, Plaintiff and Defendants agreed to the above scheduling changes before filing Motions for Summary Judgment or Adjudication on May 1, 2016;

THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff and Defendants through their designated counsel that the above scheduling changes be granted and entered by the Court.

IT IS SO STIPULATED.

Filer's Attestation: I attest under penalty of perjury that concurrence in the filing of the document has been obtained by its signatory.

The Court having considered the stipulation of the Parties, and good cause appearing therefore, orders as follows:

1. The proposed deadlines as modified by the Court above, shall be granted.

IT IS SO ORDERED.