STIPULATION AND [PROPOSED] ORDER REGARDING SCHEDULING

MAXINE M. CHESNEY, District Judge.

Pursuant to Civil L.R. 6-2, Plaintiff/Counter-Defendant Liberty Mutual Insurance Company ("Liberty Mutual") and Defendant/Counter-Claimant The California Automobile Assigned Risk Plan ("CAARP") respectfully submit this Stipulation And Proposed Order Regarding Scheduling .

WHEREAS, Liberty Mutual filed its Complaint on March 24, 2011 (Docket No. 1); CAARP filed its answer and counterclaims on May 20, 2011 (Docket No. 11); and Liberty Mutual filed its answer to CAARP's counterclaims on June 10, 2011 (Docket No. 13);

WHEREAS, on July 8, 2011, the Court, following a Case Management Conference, made a Minute Entry (Docket No. 19), and on July 14, 2011, the Court entered a Pretrial Preparation Order (Docket No. 22), which incorporated the deadlines set in the Court's Minute Entry;

WHEREAS, on February 21, 2012, pursuant to the Parties' stipulation, the Court entered an Order Modifying The Case Schedule (Docket No. 43), which modified the dates in the Court's Pretrial Preparation Order;

WHEREAS, on July 5, 2012, pursuant to the Parties' stipulation, the Court entered an Order Modifying The Case Schedule (Docket No. 57), which modified the dates in the Court's February 21, 2012 Order (Docket No. 43);

WHEREAS, on September 5, 2012, CAARP filed a motion to compel certain documents and discovery responses ("CAARP's Motion to Compel"), the briefing on the motion has been completed, and the motion is set for hearing before Magistrate Judge Jacqueline Scott Corley on October 25, 2012 at 9:00 a.m.

WHEREAS, on October 1, 2012, Liberty Mutual filed its Motion For Summary Judgment (Docket No. 87) that requested a hearing before the Court on November 9, 2012;

WHEREAS, CAARP intends to file its Motion For Summary Judgment on October 12, 2012 and to request a hearing on November 16, 2012;

WHEREAS, the Further Case Status Conference is currently scheduled to take place on October 26, 2012, with the Further Case Status Conference Statement due October 19, 2012;

WHEREAS, Objections To Experts designated by both CAARP and Liberty Mutual are due October 12, 2012;

WHEREAS, counsel for Liberty Mutual and CAARP have conferred and agreed upon the modifications to the schedule, subject to Court approval;

WHEREAS, the proposed modifications to the schedule will serve the interest of judicial efficiency by avoiding the need to have multiple hearings;

WHEREAS, the proposed modifications to the schedule will not affect the date for Trial currently scheduled to begin February 4, 2012;

THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the undersigned as follows:

IT IS SO ORDERED.