JOINT STATUS REPORT AND STIPULATION REGARDING DISCOVERY

SAMUEL CONTI, District Judge.

Plaintiff JOSE RUBIO-DELGADO and Defendant AEROTEK, INC. (collectively, the "Parties"), by and through their respective attorneys of record, hereby submit the following status report and pre-mediation discovery plan.

1. WHEREAS, the Parties attended mediation in this case on June 18, 2014, but did not reach a settlement.

2. WHEREAS, the Parties have agreed to continue settlement discussions and have scheduled a mediation for September 16, 2014.

3. WHEREAS, pursuant to this Court's Order of July 25, 2014, the Parties are to submit a Joint Status Report and Discovery Plan today.

4. WHEREAS, the Parties have held additional "meet and confer" discussions, resulting in an agreement to engage in certain formal discovery prior to their September 16 mediation that both sides believe will enhance the likelihood of a settlement being reached, without expending resources on discovery that can be deferred until after the mediation.

5. WHEREAS, the Parties have agreed that, prior to the September 16 mediation, Plaintiff will respond to certain document requests and Defendant will respond to certain requests for admission, interrogatories, and document requests.

6. WHEREAS, the Parties have agreed that the responses to the agreed upon discovery referenced in Paragraph 5 above shall be due on August 15, 2014, and that responses to all other written discovery that has been served in this case shall not be due until 30 days following the September 16 mediation, absent further agreement or court order. All objections and rights with regard to such discovery are preserved.

7. WHEREAS, the Parties have agreed that, within seven (7) days of the September 16 mediation, they will provide the Court with either notice that they have settled or an updated Joint Status Report and Discovery Plan for the remainder of the case.

WHEREFORE, the Parties jointly request that the instant Stipulation be granted, that discovery continue as outlined above, and that the Court set September 23, 2014 as the deadline for the parties to either inform the Court that they have settled or file an updated Joint Status Report and Discovery Plan for the remainder of the case.

IT IS SO STIPULATED:

[PROPOSED] ORDER

The Court grants the parties' Joint Status Report and Stipulation Regarding Discovery, and orders that, on September 23, 2014, the Parties either file a notice informing the Court that they have settled or file an updated Joint Status Report and Discovery Plan.

PURSUANT TO STIPULATION, IT IS SO ORDERED.