STIPULATION AND [PROPOSED] ORDER FOR MODIFYING AMENDED DISCOVERY AND SCHEDULING ORDER

CAROLYN K. DELANEY, Magistrate Judge.

Plaintiff Tai Huynh and Defendants Westin, Smith, Nelson and Callison, by and through their respective counsel of record, pursuant to L.R. 143 and 144, hereby stipulate as follows:

WHEREAS, on April 13, 2017 the Court issued an order setting a settlement conference to take place on November 30, 2017 before Magistrate Judge Edmund F. Brennan.

WHEREAS, the parties wish to defer discovery pending completion of the settlement conference in order to save time and costs in the event settlement is achieved.

WHEREAS, the parties sought to obtain an early settlement conference in October but were unable to secure a date in which both parties were available prior to November 30, 2017.

WHEREAS, the current deadline to complete discovery is January 8, 2018 and the deadline to file all pretrial motions, except motion to compel discovery, is April 9, 2018.

WHEREAS, the parties have not previously sought or obtained extensions as to the particular matters for which this extension is sought.

NOW THEREFORE, IT IS HEREBY STIPULATED, by and between the parties, and subject to the Court's approval, in light of the upcoming settlement conference and the parties' desire to defer discovery until after completion of the settlement conference, that the parties agree to extend all dates contained in the Court's September 8, 2017 Amended Discovery and Scheduling Order (Dkt. No. 85) by 60 days.

The agreed upon extended deadlines are as follows:

The parties respectfully request that the Court adopt the parties' agreed schedule as set forth in this Stipulation for Modifying the Amended Discovery and Scheduling Order.

ORDER

Pursuant to the foregoing stipulation, the above dates are hereby approved.