STIPULATION AND [PROPOSED] ORDER RE CONTINUANCE OF DEADLINE FOR COMPLETING MEDIATION

DONNA M. RYU, District Judge.

WHEREAS, the deadline for completing mediation in this case is currently scheduled for January 16, 2015;

WHEREAS, plaintiff has been deposed and depositions of defendant Apple, Inc.'s employees have been scheduled with the last one to be completed on January 6, 2015;

WHEREAS, the parties will not be in a position to evaluate this case for settlement until the depositions are completed on January 6, 2015;

WHEREAS, plaintiff's counsel, Kirk B. Freeman, is scheduled to begin a two week jury trial in San Francisco Superior Court in the case of Gabriel A. Jackson v. Mary A. Hughes, et. al. (Case No. CGC-12-521690 on January 12, 2015;

WHEREAS, Mr. Freeman will not have time to prepare for and participate in a mediation in this case between January 7 and 16, 2015 because of his trial committment; and

WHEREAS the parties and the mediator, Kristen Maloney, have met and conferred on a mediation date and have selected February 18, 2015 for the mediation.

NOW, THEREFORE, IT IS HEREBY STIPULATED by the parties, through their counsel of record:

1. The mediation in this case will take place on February 18, 2015;

2. For this reason the parties respectfully request that this Court continue until

February 25, 2015 the deadline for completing the mediation.

GOOD CAUSE APPEARING, IT IS HEREBY ORDERED THAT:

1. The deadline for completing the mediation in this case is continued to February 25, 2015.