STIPULATION AND PROPOSED ORDER TO RESET THE HEARING DATE AND PLAINTIFF'S TIME TO RESPOND TO DEFENDANT OMNI'S MOTION FOR SUMMARY JUDGMENT

RICHARD SEEBORG, District Judge.

Pursuant to Civil Local Rule 6-2, plaintiff Jennifer K. Lovett ("Plaintiff") and defendant Omni Hotels Management Corporation ("Defendant") stipulate as follows:

WHEREAS, Defendant Omni filed its Motion for Summary Judgment on July 2, 2015 with a requested hearing date of September 10 [Dkt. no. 59]. On July 10, the Court granted Plaintiff's Motion to Continue and set the hearing date to October 15 [Dkt. no. 68]. The Court continued, sua sponte, the hearing date, on July 17 to October 22 [Dkt. no. 71] and on September 2 to November 5 [Dkt. no. 86]. On October 5, the court granted the parties' Stipulated Motion to Specially Set or, in the Alternative, to Continue the Hearing Date and rescheduled the hearing to December 17 [Dkt. no. 102];

WHEREAS, on October 8, 2015, the Court granted Plaintiff's Motion for Leave to Amend the First Amended Complaint; denied, without prejudice, Defendant's Motion for Summary Judgment; and permitted Defendant to refile its Motion for Summary Judgment addressing Plaintiff's new claims in time for a hearing on December 17 [Dkt. no. 103];

WHEREAS, Defendant filed its Motion for Summary Judgment on November 12 with a hearing date of December 17 [Dkt. no.108];

WHEREAS, Plaintiff's opposition to Defendant's Motion for Summary Judgment is due on November 27, 2015;

WHEREAS, Plaintiff's counsel is commencing trial in another matter, Yuan v. City and County of San Francisco, San Francisco Superior Court Case No. CGC-13-536533 before Honorable Angela Bradstreet, and pre-trial motions shall be argued on November 19, 2015 and jury selection to commence on November 23 or 24, 2015;

WHEREAS, Plaintiff's counsel anticipates being in trial until shortly before Christmas;

WHEREAS, the parties have now met and conferred on mutually convenient dates for the hearing and Plaintiff's last date to oppose Defendant Omni's Motion for Summary Judgment;

IT IS THEREFORE STIPULATED as follows:

1. Defendant Omni's Motion for Summary Judgment shall be heard on January 21, 2016;

2. Plaintiff shall file her Opposition to the Motion for Summary Judgment no later than January 7, 2016.

IT IS SO ORDERED.