STIPULATION AND PROPOSED ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE AND EXTENDING THE DEADLINE FOR COMPLETION OF PRIVATE ADR

MAXINE M. CHESNEY, District Judge.

Plaintiff Andrea Jesse and Defendant Study Group USA, by and through their counsel of record, hereby stipulate and agree as follows:

WHEREAS, the Court scheduled the Initial Case Management Conference for December 21, 2012; and

WHEREAS, the Court on December 3, 2012 entered its order referring this matter to private ADR and setting a deadline to complete the ADR within ninety (90) days from the date of the Court's order; and

WHEREAS, Plaintiff Jesse's counsel of record in this matter, John F Hyland, Rosha Jones, and Rukin Hyland Doria & Tindall LLP, intend to file a motion to withdraw as counsel in this case; and

WHEREAS, the parties believe it would best serve the interests of the Court and the parties to conduct the Initial Case Management Conference after the Court has ruled on the motion to withdraw and Plaintiff Jesse has retained new counsel to represent her in this matter;

WHEREAS, the parties believe they can most effectively and efficiently conduct private ADR after the Court has ruled on the motion to withdraw and Plaintiff Jesse has retained new counsel to represent her in this matter and in the ADR process; and

WHEREAS, the parties do not believe that continuance of the Initial Case Management Conference or extension of the deadline to complete ADR will cause undue prejudice to any party;

IT IS HEREBY STIPULATED AND AGREED that the Court should continue the Initial Case Management Conference for ninety (90) days to allow sufficient time for Plaintiff Jesse's counsel of record in this case to file its motion to withdraw as counsel, for the Court to consider and rule on the motion, for Plaintiff Jesse to retain new counsel to represent her in this matter, and for such new counsel to familiarize himself or herself such that he or she can meaningfully participate in the Initial Case Management Conference. The parties further STIPULATE AND AGREE that the Court should extend the deadline for completion of the private ADR to which the Court ordered this matter until a date no earlier than sixty (60) days from the continued date of the Case Management Conference.

ORDER

The Court, having considered the Stipulation of the parties and having concluded that the constitutes good cause for the continuance of the Initial Case Management Conference and extension of the deadline by which the parties must complete private ADR, hereby continues the Conference until March 2, 2013. The Parties shall submit a Joint Report no later than seven (7) days prior to the Conference. The Parties shall complete private ADR no later than sixty (60) days from the date of the Conference.

IT IS SO ORDERED.