JOINT STIPULATION AND PROPOSED ORDER TO EXTEND FILING DEADLINES AND HEARING DATE FOR CROSS-MOTIONS FOR SUMMARY JUDGMENT AND PROPOSED ORDER

VINCE CHHABRIA, District Judge.

Plaintiffs and Counterdefendants American Home Assurance Company ("American Home") and Insurance Company of the State of Pennsylvania ("ISOP"), Defendants and Counterclaimants SMG Stone Company, Inc., J Colavin & Son, Inc., Webcor Construction LP dba Webcor Builders and dba Webcor Construction, Inc. and Defendant Steadfast Insurance Company (referred collectively as "Webcor") (American Home, ISOP and Webcor are jointly referenced as "Parties") hereby stipulate and present this Joint Stipulation To Extend Filing Deadlines And Hearing Date For Cross-Motions For Summary Judgment And Proposed Order from those set forth in the Court's Minute Order of October 7, 2014.

WHEREAS on October 7, 2014, and in conjunction with the Parties' Joint Case Management Statement and comments made by counsel at the Case Management Conference on October 7, 2014, via Minute Order the Court entered the following applicable deadlines in connection with the Parties' Cross-Motions for Summary Judgment: (1) Plaintiffs' Opening Brief due on October 17, 2014; (2) Defendants' Opening Brief due on November 7, 2014; (3) Plaintiffs' Reply Brief/Cross-Motion Opposition due on November 21, 2014; (4) Defendants' Reply Brief due on December 5, 2014; and (5) Cross-Motions hearing date on January 22, 2015 at 10:00 a.m. (See Docket Entry no. 42 [10/7/2014].) Via the same Minute Order, and based on the Parties' stated preference for mediation prior to the hearing on the Cross-Motions, the Court referred the case to the Court's ADR Program to "take place in December 2014." (Id.);

WHEREAS on October 17, 2014, Plaintiffs' counsel filed their Opening Brief and on November 7, 2014, Defendants' counsel filed their Opening Brief as required by the Court's Minute Order of December 7, 2014;

WHEREAS after the filing of the Parties' Opening Briefs, counsel for the Parties met and conferred to develop a modified briefing schedule for the Cross-Motions in order to accommodate newly-developed scheduling pressures brought about by professional and familial obligations of the Parties and counsel including, but not limited to, the holiday schedule including Thanksgiving, Christmas and New Year's Eve, as follows: (1) December 8, 2014 for the filing of Plaintiffs' Reply Brief/Cross-Motion Opposition; and (2) January 8, 2015 for the filing of Defendants' Reply Brief;

WHEREAS counsel for the Parties determine that while the proposed, revised briefing schedule would accommodate the previously-scheduled January 22, 2014 hearing date under the Court's Standing Order requiring a minimum of fourteen (14) days between the filing of the last reply brief and the hearing, it would not accommodate the Court's Minute Order requiring mediation between the time of the filing of the last reply brief and the hearing on the Cross-Motions, such that counsel agreed that: (1) the hearing date on the Cross-Motions should be continued from January 22, 2015 to a date after March 16, 2015 which is convenient for the Court; (2) the Court's referral of the parties to the court's ADR Program for mediation should have a completion deadline which is the same as the date of the hearing on the Cross-Motions; and (3) the further case management conference scheduled for February 10, 2015 and the concurrent, updated joint case management statement filing deadline of February 3, 2015, should be continued to an appropriate date after the hearing on the Cross-Motions.

NOW THEREFORE, the Parties hereby stipulate by their counsel of record that: (1) the current deadline for the filing of Plaintiffs' Reply Brief/Cross Motion Opposition be continued from November 21, 2014 to December 8, 2014; (2) the current deadline for the filing of Defendants' Reply Brief be continued from December 5, 2014 to January 8, 2015; (3) the current hearing date for the Cross-Motions be continued from January 22, 2015 to a date after March 16, 2015 which is convenient for the Court; (4) the current deadline for the Parties' participation in mediation in conjunction with the court's ADR Program be continued from "December, 2014," to the new hearing date on the parties' Cross-Motions; and (5) the further case management conference scheduled for February 10, 2015 and the concurrent, updated joint case management statement filing deadline of February 3, 2015, be continued to appropriate dates after the hearing on the Cross-Motions.

IT IS SO STIPULATED.

[PROPOSED] ORDER OF COURT

AND NOW, this 21st day of November, 2014, upon consideration of the Parties' JOINT STIPULATION TO EXTEND FILING DEADLINES AND HEARING DATE FOR CROS-MOTIONS FOR SUMMARY JUDGMENT, it is hereby ordered as follows:

(1) The current deadline for the filing of Plaintiffs' Reply Brief/Cross Motion Opposition is continued from November 21, 2014 to December 8, 2014;

(2) The current deadline for the filing of Defendants' Reply Brief is continued from December 5, 2014 to January 8, 2015;

(3) The current hearing date for the Cross-Motions is continued from January 22, 2015 to March 26, 2015;

(4) The deadline for the Parties' participation in mediation in conjunction with the court's ADR Program is continued from December, 2014, to March 26, 2015, the new hearing date on the Parties' Cross-Motions;

(5) The date for the further case management conference is continued from February 10, 2015 to April 14, 2015, and the Parties shall be required to file an updated joint case management statement seven (7) days prior to the date of the further case management conference. Counsel for the Parties may attend by telephone upon notice to the Court no less than twenty-four hours prior to the further status conference.