STIPULATED REQUEST FOR SETTLEMENT CONFERENCE; [PROPOSED] ORDER THEREON

TROY L. NUNLEY, District Judge.

WHEREAS, the parties are interested in resolving this matter without unnecessary litigation;

WHEREAS, the parties have scheduled a settlement-protected meeting among all experts and counsel in this case on September 5, 2019, to explore a comprehensive, early resolution of this matter;

WHEREAS, Plaintiff has committed to making best efforts to provide Defendant with a written demand, including all injunctive and monetary terms, as well as a draft consent decree on or before September 20, 2019;

WHEREAS, Defendant has committed to making best efforts to provide a written response to Plaintiff's demand, including a mark-up of the draft consent decree, on or before October 11, 2019;

WHEREAS, the parties have contacted Magistrate Judge Newman's clerk and obtained Judge Newman's agreement to convene a settlement conference on October 23, 2019.

THEREFORE, the parties request that the Court order the parties to participate in a settlement conference with Magistrate Judge Newman on October 23, 2019 at 9:00 a.m.;

AND THEREFORE, the parties hereby waive any claim of disqualification of the assigned Magistrate Judge on the basis of Magistrate Judge Newman's participation in a settlement conference in this action.

ORDER

The parties are ORDERED to participate in a settlement conference with Magistrate Judge Newman on October 23, 2019 at 9:00 a.m. in Courtroom 25, on the 8th floor of the Robert T. Matsui United States Courthouse located at 501 I Street in Sacramento, California.