STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE DEADLINES SET IN THE COURT'S CASE MANAGEMENT AND PRETRIAL ORDER FOR JURY TRIAL FILED MAY 10, 2013 PURSUANT TO LOCAL RULE 6-2(a)

EDWARD M. CHEN, District Judge.

Pursuant to United States District Court of the Northern District of California's Local Rule ("Local Rule") 6-2(a), Plaintiff Kristinna Grotz ("Plaintiff") Defendant Kaiser Foundation Hospitals ("Kaiser") and SEIU-United Healthcare Workers West ("SEIU") (collectively the "Parties"), by and through their respective counsel of record, hereby stipulate to revise the Court's Case Management and Pretrial Order for Jury Trial as follows:

WHEREAS, on May 10, 2013 the Court filed a Case Management and Pretrial Order for Jury Trial in this case;

WHEREAS, the Parties have not previously sought to continue or extend any of the deadlines set by the Court's Case Management and Pretrial Order;

WHEREAS, the Parties are engaged in discovery and require additional time to complete key depositions and discovery in this case; and

WHEREAS, the Parties seek the opportunity to engage in further settlement negotiations after the completion of the key depositions.

NOW, THEREFORE,

IT IS HEREBY STIPULATED AND AGREED by and between the Parties, by and through their respective undersigned attorneys of record, that, pursuant to Local Rule 6-2(a), and having met and conferred regarding their respective calendars and availability, that the dates set by the Case Management and Pretrial Order be continued, as follows:

IT IS SO STIPULATED:

ORDER

Having reviewed the Stipulation executed by Plaintiff KRISTINNA GROTZ, Defendant KAISER FOUNDATION HOSPITALS and Defendant SEIU-UNITED HEALTHCARE WORKERS WEST and good cause appearing, the Court hereby orders that the dates set by the Case Management and Pretrial Order be continued, as follows:

PURSUANT TO STIPULATION, IT IS SO ORDERED.