STIPULATION RE: SUMMARY JUDGMENT DEADLINES; [PROPOSED ] ORDER

WILLIAM B. SHUBB, District Judge.

TO THE CLERK OF THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

Plaintiff JOANNE BLIGHT ("Plaintiff") and Defendants CITY OF MANTECA, ARMANDO GARCIA, IAN OSBORN, CHRIS MRAZ, and PAUL CARMONA ("Defendants") are hereby respectfully requesting continuance of the existing hearing date (9/18/17) so that Defendants have additional time to complete the Reply. The parties request October 16, 2017 (which they understand is the next available hearing date). Defendants agree to waive Local Rule 230(d); their Reply would be Monday, September 18, 2017.

I. GOOD CAUSE

The record in this matter is voluminous, and Plaintiff's combined statement of facts/opposition brief is lengthy. Despite defense counsel's best efforts, the Reply cannot be completed by the September 11th deadline.1 In view of the length of Plaintiff's opposition brief and separate statement of facts (combined into one document), Plaintiff does not object to Defendants' request.

Based on the foregoing circumstances, by and through their respective counsel of record, the parties hereby stipulate, and respectfully request that the briefing schedule relating to Defendants' motion for summary judgment/adjudication and, as a result, the hearing date on Defendants' motion, be continued and modified, as follows:

1. That the hearing date for Defendants' Motion for Summary Judgment/Adjudication be continued from September 18, 2017 to October 16, 2017 at 1:30 p.m.

2. Defendants' deadline to file their Reply is September 18, 2017 by Noon (12:00 p.m.)

PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED.