STIPULATION AND (PROPOSED) ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE

WILLIAM H. ALSUP, District Judge.

Plaintiff THERESA ANTMAN ("Plaintiff") and Defendant BLUE SHIELD LIFE AND HEALTH INSURANCE COMPANY, hereby stipulate as follows:

WHEREAS, Plaintiff filed a Complaint in the United States District Court, Northern District of California on August 7, 2014;

WHEREAS, Plaintiff filed a Notice of Errata to Complaint on September 11, 2014;

WHEREAS, this Court initially set this matter for an Initial Case Management Conference on November 4, 2014;

WHEREAS, on September 17, 2014, Defendant filed an Answer in the above-referenced matter;

WHEREAS, Defendant filed a Notice of Declining Magistrate Jurisdiction on October 1, 2014;

WHEREAS, on October 6, 2014, Judge Alsup was reassigned to this case;

WHEREAS, this case is currently scheduled for an Initial Case Management Conference on Thursday, November 6, 2014, at 11:00 a.m., pursuant to the Clerk's Notice Setting Initial Case Management Conference dated October 22, 2014;

WHEREAS, Glenn R. Kantor, the lead counsel for Plaintiff Theresa Antman wishes personally to attend the Initial Case Management Conference, but he is not available on the date and time presently scheduled;

WHEREAS, before Plaintiff had even filed this lawsuit which resulted in this Court's Order setting the Initial Case Management Conference, Plaintiff's counsel, Glenn R. Kantor, had scheduled to be out-of-state on November 6, 2014;

WHEREAS, immediately after the Court issued the Initial Case Management Conference Order, Mr. Kantor contacted Defendant's counsel, John M. LeBlanc, to discuss his unavailability for November 6 and the need to continue the Initial Case Management Conference to November 20, 2014. Mr. LeBlanc agreed that the parties should request a continuance. He likewise advised Mr. Kantor that he would be out-of-state on November 20, 2014 representing a client in another matter.

Due to these circumstances, both counsel agreed to request a continuance of the Initial Case Management Conference to December 4, 2014, at 11:00 a.m.

Based on the foregoing, the parties respectfully request that the Court continue the Initial Case Management Conference to Thursday, December 4, 2014, at 11:00 a.m. The parties likewise request that the deadline for filing the CMC statement be continued to one week before any new Initial Case Management Conference date;

NOW THEREFORE, it is hereby stipulated and agreed, subject to the Court's approval, that the Initial Case Management Conference, currently scheduled for November 6, 2014, at 11:00 am, may be continued to Thursday, December 4, at 11:00 a.m., or such other date that all counsel are available as the Court may allow.

[PROPOSED] ORDER

The Court having considered the parties' stipulation and good cause appearing therefore, IT IS HEREBY ORDERED that the Initial Case Management Conference currently scheduled for October 6, 2014 is continued to November 12, 2014, by November 5, 2014. at 8:00 a.m. Please file a joint statement