JOINT STIPULATION AND PROPOSED ORDER TO AMEND CASE MANAGEMENT SCHEDULING ORDER TO CONTINUE THE INITIAL EXPERT DISCLOSURE DATE BY SEVENTEEN DAYS AND THE SUPPLEMENTAL EXPERT DISCLOSURE DATE BY ONE WEEK

RICHARD SEEBORG, District Judge.

Plaintiffs MEENAKASHI SAWHNEY and RMHNS, INC., dba New Dannys Restaurant (hereinafter "Plaintiffs") and Defendant AMCO INSURANCE COMPANY (hereinafter "Defendant"), by and through their counsel of record, jointly submit the following Stipulation to amend the Case Management Scheduling Order to continue the initial expert disclosure date by seventeen days and the supplemental expert disclosure date by one week in order to allow the parties to complete ongoing settlement negotiations without incurring unnecessary experts fees and expenses and the impact of such expenses on ongoing settlement negotiations.

RECITALS

1. WHEREAS, the parties have been engaged in settlement negotiations since the beginning of 2014 but, due to serious health issues experienced by Plaintiff and Plaintiff's subsequent attendance at a funeral out of the country, such negotiations were halted or stalled until three weeks ago but have since resumed and are ongoing.

2. WHEREAS, settlement offers and counter-demands have been exchanged and the parties are narrowing the gap in this regard but because of vacations being taken by certain AMCO claims managers and directors during the upcoming Fourth of July holiday next week, AMCO is unable to fully consider and respond further to Plaintiff's pending settlement counter-demand until after next week.

3. WHEREAS, pursuant to the Court's Case Management Scheduling Order in this matter the initial designation date for experts is July 1, 2014 and the supplemental designation date is July 22, 2014.

4. WHEREAS, AMCO has already incurred expenses in relation to its anticipated expert designation but Plaintiff has not yet incurred such expenses and such expenses will impact the value of Plaintiff's pending counter-demand and ability or willingness to accept any forthcoming counter offer by AMCO.

5. WHEREAS, the parties seek a 17 day continuance of the initial expert designation date from July 1, 2014 to July 18, 2014 and a one week continuance of the supplemental expert designation date from July 22, 2014 to July 29, 2014 to allow AMCO adequate time to consider and respond to Plaintiff's most recent counter demand without the amount of that demand being impacted by Plaintiff's expert fees and costs.

6. WHEREAS, the requested continuance will not impact any other date set in this matter and this is the first request of the parties for any continuance.

STIPULATION

The parties stipulate and agree to a seventeen day continuance of the initial expert designation date from July 1, 2014 to July 18, 2014 and a one week continuance of the supplemental expert designation date from July 22, 2014 to July 29, 2014.

Federal Rules of Civil Procedure 6(b), 16(a) and 16(b)(4) give the Court broad discretion to regulate pre-trial matters, to manage its calendar, grant continuance of scheduling dates, and to direct the parties in a manner that expedites disposition of the action and facilitates settlement. As set forth herein, good cause exists for the Court to grant the continuance under any of the Rules.

SO STIPULATED.

ATTESTATION OF CONCURRENCE IN FILING

I hereby attest and certify that on June 26, 2014, I received concurrence from Plaintiff's counsel, David Golden, to file this document with his electronic signature attached.

I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on June 26, 2014.

ORDER AMENDING THE CASE MANAGEMENT SCHEDULING ORDER

The Case Management Scheduling Order is hereby amended as follows:

The date for initial designation of experts is hereby continued from July 1, 2014 to July 18, 2014 and the date for supplemental and rebuttal designation of experts is hereby continued from July 22, 2014 to July 29, 2014. Designation shall be in accordance with Federal Rule of Civil Procedure 26(a)(2).