JOINT MOTION FOR ORDER CONTINUING DEFENDANT, CITIBANK, N.A.'S APRIL 23, 2015 FED. R. CIV. P. 11(B) MOTION FOR SANCTIONS TO MAY 7, 2015 [LOCAL RULE 7-12]

WILLIAM ALSUP, District Judge.

On December 31, 2014, Plaintiff filed her First Amended Complaint in this matter. See Dkt. #10. On or about March 19, 2015, Citibank, N.A. ("Defendant"), filed a Fed R. Civ. P. 11(b) Motion for Sanctions against Plaintiff's counsel. See Dkt. #41. Defendant's Fed R. Civ. P. 11(b) Motion for Sanctions is set to heard at 8:00 AM on April 23, 2015.

Plaintiff's counsel, whom plans on being present at the Fed R. Civ. P. 11(b) Motion for Sanctions hearing date, will be in Cancun, Mexico on April 23, 2015, for the wedding of Sara Khosroabadi, an Associate with Plaintiff's counsel's law firm, Hyde & Swigart. As a result, Plaintiff's counsel will be unable to participate at the April 23, 2015 Fed R. Civ. P. 11(b) Motion for Sanctions hearing date. Similarly, counsel for Defendant will be attending a family wedding the following week in Florida. Accordingly, the soonest available date for the parties is May 7, 2015.

Plaintiff and Defendant, by and through their counsel, hereby stipulate to a continuance of Defendant's April 23, 2015 Fed R. Civ. P. 11(b) Motion for Sanctions hearing date to May 7, 2015, at 8:00 AM, in accordance with Your Honor's scheduling notes, and respectfully request an Order approving these circumstances.

WHEREFORE, for the foregoing reasons, the parties respectfully request an Order approving the Parties stipulation and a continuance of Defendant's Fed R. Civ. P. 11(b) Motion for Sanctions hearing date to May 7, 2015.

PURSUANT TO STIPULATION, IT IS SO ORDERED:

1. Defendant, Citibank, N.A.`s April 23, 2015 Fed R. Civ. P. 11(b) Motion for Sanctions hearing date is rescheduled to May 7, 2015 at 8:00 AM. 2:00 P.M.