STIPULATION TO CONTINUE HEARING DATE OF PLAINTIFF TITAN INDEMNITY COMPANY'S MOTION FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER

WILLIAM ALSUP, District Judge.

Plaintiff Titan Indemnity Company ("Titan") and Defendant Katrina Rapp, ("Defendant Rapp") hereby stipulates as follows:

1. The hearing on Titan's Motion for Summary Judgment is currently schedule for September 3, 2015 at 8:00 a.m.

2. On July 30, 2015, Titan filed its Notice of Motion and Motion for Summary Judgment.

3. On July 31, 2015, Defendant Rapp promptly contacted Titan and asked if Titan would be willing to continue the hearing in order to extend Defendant Rapp's response presently due on August 13, 2015. Defendant Rapp's counsel is schedule to leave on a long planned family vacation on August 7, 2015 and will not be returning to the office until August 24, 2015.

4. On August 3, 2015, Titan agreed to continue the hearing until September 17, 2015.

5. In light of the foregoing, the parties respectfully request that the hearing on the Motion for Summary Judgment be continued to September 17, 2015 at 8:00 a.m. and that all associated deadlines be continued accordingly.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Pursuant to stipulation of the parties, and good cause appearing therefore, it is hereby ordered that:

1. The date for Plaintiff Titan Indemnity Company's hearing on the Motion for Summary Judgment has been continued from September 3, 2015 to September 17, 2015 at 8:00 a.m.

2. All deadlines associated with the Motion shall be continued accordingly.

Plaintiff's opposition is now due on August 27, 2015. Defendant's reply is due on September 3, 2015.

IT IS SO ORDERED.