STIPULATION TO MODIFY CASE MANAGEMENT ORDER AS TO FACT DISCOVERY CUTOFF; [PROPOSED] ORDER

HOWARD R. LLOYD, District Judge.

Plaintiff HOAN PHAM ("Plaintiff") and Defendants JPMORGAN CHASE BANK, N.A., successor by merger to CHASE HOME FINANCE, LLC ("Chase") and REDLINE RECOVERY SERVICES, LLC ("Redline") (collectively, the "Parties"), by and through their respective counsel of record, hereby stipulate and agree as follows:

WHEREAS, on July 31, 2013, this court issued a Case Management Order providing for a fact discovery cut-off date of January 28, 2014;

WHEREAS, the Parties stipulated to extend the fact discovery cut-off date to March 18, 2014, and the Court issued an Order on that stipulation on January 13, 2014;

WHEREAS, the Parties are currently engaged in settlement discussions, and wish to extend the fact discovery cut-off date in order to continue to facilitate those discussions;

WHEREAS, the Parties are desirous of changing the fact discovery cut-off date to April 1, 2014, with the deadline to respond to written discovery extended to March 17, 2014, and all depositions to be held no earlier than the week of March 17, 2014;

WHEREAS, good cause exists to enter an order modifying the fact discovery cut-off date in that it will not affect any other date in the current Case Management Order, including the date of the Pretrial Conference;

IT IS HEREBY STIPULATED by and between all Parties to this action through their respective counsel that the fact discovery cut-off date should be reset to April 1, 2014, with the deadline to respond to written discovery extended to March 17, 2014, and all depositions to be held no earlier than the week of March 17, 2014.

[PROPOSED] ORDER

PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS HEREBY ORDERED THAT the Case Management Order issued July 31, 2013 should be and hereby is modified to reflect a Fact Discovery Cutoff date of April 1, 2014.

IT IS SO ORDERED.