STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL AND TRIAL-RELATED DATES AS MODIFIED AS MODIFIED

ELIZABETH D. LAPORTE, Magistrate Judge.

Plaintiff Tracey Thompson and Defendant Patrick R. Donahoe, Postmaster General of the United States, by and through their respective counsel of record, hereby stipulate as follows:

1. On April 6, 2011, Plaintiff, appearing pro se, commenced this action in the United States District Court for the Northern District of California. See Doc

2. On August 11, 2011, Defendant filed a motion to dismiss Plaintiff's Complaint. See Docket No. 18.

3. On September 16, 2011, Plaintiff filed a Notice of Appearance by attorney Dennis Wright. See Docket No. 31.

4. On September 20, 2011, the Court granted Defendant's motion to dismiss with leave to amend. See Docket No. 32.

5. On January 11, 2012, Plaintiff filed a substitution of attorney, substituting attorney Dolores Victor for attorney Dennis Wright. See Docket No. 39.

6. On January 12, 2012, Plaintiff filed a First Amended Complaint, and on January 26, 2012, Defendant filed a motion to dismiss Plaintiff's newest complaint for lack of subject matter jurisdiction and failure to state a claim against Defendant. See Docket No. 44. On March 30, 2012, the Court granted in part and denied in part Defendant's motion to dismiss. Docket No. 51.

7. On April 9, 2012, Plaintiff filed her Second Amended Complaint, and on April 23, 2012, Defendant filed an answer. Docket Nos. 52 and 54.

8. The parties attended a mediation on July 13, 2012, but were unable to resolve this case.

9. On July 20, 2012, Defendant served written discovery requests in this case and originally noticed Plaintiff's deposition for September 10, 2012. (The parties had agreed to a discovery hold prior to the July 13, 2012 mediation.) Shortly before September 10, 2012, the parties agreed to take the deposition off calendar until Plaintiff had responded to Defendant's written discovery requests. To date, Plaintiff has not provided Defendant with verified responses to its discovery requests. In addition, Plaintiff has served no discovery requests and noticed no depositions in this matter.

10. On September 4, 2012, the Court set the following trial and trial-related dates:

See Docket No. 66.

11. On or about October 25, 2012, Plaintiff filed a third notice of substitution of counsel, replacing Dolores Victor with Keith Oliver. See Docket No. 67.

12. On November 16, 2012, and after meeting and conferring with Plaintiff's counsel, Defendant re-noticed the deposition of Plaintiff, which is scheduled to take place on December 12, 2012.

13. The parties wish to move this case forward in a timely fashion; however, the frequent changes in Plaintiff's representation, and its implications on the case, have resulted in a delay in prosecution.

14. Based on the foregoing, the parties request the following continuances:

15. The parties have not made any prior requests to continue the trial date in this case.

PROPOSED ORDER AS MODIFIED

PURSUANT TO STIPULATION, IT IS SO ORDERED:

The Court vacates the original trial and trial-related dates and orders the following dates:

It is further ordered that the parties shall comply with the Standing Order for Civil Case Practice in Cases Assigned for All Purposes to Magistrate Judge Laporte, a copy of which is available from the Clerk of the Court and on the Court's website, with regard to the timing and content of the Joint Pretrial Statement, and all other pretrial submissions.