SECOND STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES FOR OPPOSITION AND REPLY TO DEFENDANTS' MOTION FOR JUDGMENT ON THE PLEADINGS

RICHARD SEEBORG, District Judge.

Pursuant to Local Rules 6-2 and 7-12, Plaintiff Jaimen Joaquin Dominiquez ("Plaintiff") and Defendants, by and through their undersigned counsel, hereby stipulate and request as follows:

WHEREAS, on March 20, 2014 Defendants filed a Notice of Motion and Motion for

Judgment on the Pleadings ("Motion") pursuant to FRCP 12(c) (ECF No. 33);

WHEREAS, on March 20, 2014 the Court entered the following schedule in the docket for this action (see ECF No. 33):

1. Responses (i.e. Opposition) to Defendants' Motion due by April 3, 2014.

2. Reply due by April 10, 2014.

3. Hearing set for May 29, 2014 at 1:30 p.m. WHEREAS, one modification was previously made in this matter by Stipulation and

Order (ECF No. 36) on March 24, 2014, extending the Opposition deadline from April 3, 2014 to May 15, 2014, and extending the Reply deadline from April 10, 2014 to May 22, 2014;

WHEREAS, the parties attended a mediation session with mediator Mark LeHocky on April 8, 2014;

WHEREAS, the parties subsequently reached a settlement in principle on April 12, 2014;

WHEREAS, the parties require additional time to mutually negotiate, prepare, and execute a Settlement Agreement;

WHEREAS, the parties wish to complete the settlement process without incurring further or unnecessary litigation expenses;

WHEREAS, counsel for Plaintiff is travelling internationally from May 3, 2014 until May 14, 2014;

WHEREAS, in light of the parties' ongoing cooperation to finalize and execute a Settlement Agreement and their need for additional time to do so, the parties request that the current deadlines for the Opposition and Reply to Defendants' Motion be further extended and that the hearing date for Defendants' Motion be continued;

IT IS HEREBY STIPULATED by and between the parties, through their respective counsel:

The deadline for Plaintiff to file and serve his Opposition to Defendants' Motion for

Judgment on the Pleadings is extended to June 26, 2014.

The deadline for Defendants to file and serve their Reply to Plaintiff's Opposition is extended to July 3, 2014.

The hearing scheduled for May 29, 2014 at 1:30 p.m. shall be continued to July 24, 2014 at 1:30 p.m., or the next available hearing date thereafter.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.