STIPULATION AND ORDER TO EXTEND TRIAL AND DEADLINES

CAROLYN K. DELANEY, Magistrate Judge.

Defendants Linder Psychiatric Group, Inc., David Linder, M.D., and Renae Linder ("Defendants") and Joelle Stallsmith ("Plaintiff"), by and through their respective counsel, hereby stipulate as follows:

WHEREAS, on July 2, 2015, the Status (Pretrial Scheduling) Order was filed.

WHEREAS, Trial in the instant action is currently scheduled for September 26, 2016.

WHEREAS, the Final Pretrial Conference is currently scheduled for July 27, 2016.

WHEREAS, all pretrial law and motion shall be completed by June 29, 2016.

WHEREAS, the Parties are engaging in good faith early settlement discussions;

WHEREAS, the Parties have recently agreed to explore potential resolution of this matter through the Court's Voluntary Dispute Resolution Program ("VDRP").

WHEREAS, the Parties desire to focus their efforts and resources on potential resolution of this matter and postpone costly trial preparation for a brief period of time;

WHEREAS, the Parties agree that there is good cause to continue the trial date and all applicable deadlines for at least ninety (90) days in order to facilitate good faith settlement negotiations between the Parties without incurring unnecessary costs and fees associated with trial preparation;

WHEREAS, continuance is necessary to avoid the Parties incurring unnecessary filing costs;

WHEREAS, this Stipulation is not entered into with the intent to delay. By continuing of the trial and applicable deadlines, there will be no prejudice to any party or to any of the witnesses involved in the case;

WHEREAS, the Parties have not previously sought any prior continuances; and

WHEREAS, the current trial date has not been previously continued by this Court.

STIPULATION

IT IS HEREBY STIPULATED by all Parties, through their respective counsel, that:

1. The trial of this matter be continued from September 26, 2016 to February 6, 2017, or to a later date decided upon by the Court.

2. The deadline for all pretrial law and motion shall be continued at least (90) days from June 29, 2016 to September 29, 2016, or a later date decided upon by the Court.

3. All pre-trial deadlines and dates shall be extended in accordance with the new trial date.

4. This Stipulation may be executed in counterparts, each of which shall be deemed an original and all of which shall constitute one and the same Stipulation.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Discovery cut-off is continued to July, 27, 2016.

Law and motion cut-off is continued to September 28, 2016.

Pretrial conference is continued to January 11, 2017 at 11:00 a.m.

Trial is continued to February 6, 2017 at 9:00 a.m.