STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE ON PLAINTIFFS' ADDITIONAL MOTIONS FOR SUMMARY JUDGMENT AGAINST MB ENTERPRISES, INC. AND GREGORY VILLAGE PARTNERS, L.P.

JON S. TIGAR, District Judge.

1. By Order dated December 8, 2014 (docket # 131), the Court established a briefing schedule with respect to Plaintiffs' request to file additional motions for summary judgment against Defendants MB Enterprises', Inc. and Gregory Village Partners, L.P. Under that schedule, Plaintiffs were provided the ability to file their additional summary judgment motions with respect to liability on selected causes of action against these Defendants no later than January 30, 2015. Defendants' opposition papers were to be filed by March 4, 2015. Plaintiffs' reply papers were to be filed by March 18, 2015. The motions were set for hearing on April 9, 2015.

2. After the Court issued that Order, counsel for Defendant MB Enterprises, Inc. received an Order from Judge William B. Shubb in the Eastern District of California. By that Order, Judge Shubb re-calendared the commencement of a jury trial from January 13, 2015 to February 3, 2015. MB Enterprises' counsel represents the Defendants in that jury trial, which is estimated to last three weeks. This trial will prevent counsel from preparing and filing opposition papers by March 4, 2015.

WHEREFORE, Plaintiffs, Gregory Village, and MBE stipulate to and respectfully request that this Court amend the existing filing deadlines for Plaintiffs' additional summary judgment motions against Gregory Village and MBE, related filing deadlines, and the date for hearing on both summary judgment motions as follows:

PROPOSED ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED that this Court amends the existing filing deadlines and hearing date set forth in Docket Number 131 in this matter to incorporate the dates proposed above.

IT IS SO ORDERED.