THIRD STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANT TO RESPOND TO COMPLAINT AND ADJOURNING INITIAL CASE MANAGEMENT CONFERENCE

MARIA-ELENA JAMES, District Judge.

By this Stipulation and Proposed Order, the parties respectfully request that the time for Defendant to answer, move or otherwise respond to the Complaint be extended, and the Initial Case Management Conference be adjourned, for the reasons stated below:

WHEREAS, the Complaint was filed on March 18, 2013; WHEREAS, the time for Defendant to answer, move or otherwise respond to the Complaint was first extended to May 17, 2013 by stipulation [ECF No. 7];

WHEREAS, the time for Defendant to answer, move or otherwise respond to the Complaint was next extended to June 17, 2013 by stipulation and Order of this Court [ECF No. 9];

WHEREAS, the parties have engaged in settlement discussions;

WHEREAS, the parties have reached an agreement in principle and are in the process of negotiating a settlement agreement;

WHEREAS, the parties have therefore agreed on an extension of the deadline for Defendant to answer, move or otherwise respond to the Complaint through July 1, 2013;

WHEREAS, the Court has scheduled an Initial Case Management Conference for August 8, 2013 at 10:00 a.m. [ECF No. 9]; and

WHEREAS, the parties seek the extension and adjournment to allow them to focus on finalizing the settlement agreement;

NOW THEREFORE, the parties hereby agree and stipulate to an extension of the date by which Defendant must answer, move or otherwise respond to the Complaint through and including July 1, 2013, and request that the Court adjourn the Initial Case Management Conference to a date at least 35 days after July 1, 2013.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED that the Court's May 9, 2013 Order is modified as follows:

1. The August 8, 2013 Initial Case Management Conference shall be continued to September 5, 2013 at 10:00 a.m., Courtroom B, 15th Floor. If the parties, settle prior to the CMC, they shall notify the Court immediately.

2. Defendant shall answer, move or otherwise respond to the Complaint on or before July 1, 2013.

3. The parties shall file their Fed. R. Civ. P. 26(f) Report and complete their initial disclosures under Fed. R. Civ. P. 26(a)(1) no later than seven (7) days before the Initial Case Management Conference.