STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

SUSAN ILLSTON, District Court Judge.

Pursuant to Civil local Rules 7-12 and 16-2, Plaintiffs, The Board of Trustees, in their capacities as Trustees of the Laborers Health and Welfare Trust Fund for Northern California; Laborers Vacation-Holiday Trust Fund for Northern California; Laborers Pension Trust Fund for Northern California; and Laborers Training and Retraining Trust Fund for Northern California (hereinafter "Trust Funds" or "Plaintiffs"), by and through their undersigned counsel, and Defendant, Geo Grout, Inc. (hereinafter referred to as "Defendant"), by and through the undersigned counsel, hereby respectfully request that the scheduled for January 17, 2014 at 2:30pm be continued for 30 days.

The parties have been actively engaged in settlement negotiations in this matter, and are finalizing a written settlement agreement. The parties are confident they will be able to fully resolve this matter prior to any rescheduled Case Management Conference. Once the agreement is finalized, the parties will submit a Notice of Settlement; any further dates may be vacated at that time. Accordingly, the parties respectfully request that the January 17, 2014 Case Management Conference be continued for thirty days.

[PROPOSED] ORDER

Based upon the foregoing Stipulation to Continue Case Management Conference, the Court orders the continuance of the January 17, 2014 Case Management Conference for thirty (30) days, or as soon thereafter as a court date is available. In addition, the Court Orders: The initial case management conference is continued to Friday, February 28, 2014.