STIPULATED REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

THELTON E. HENDERSON, Senior District Judge.

STIPULATION AND REQUEST

Plaintiff East Bay Law ("Plaintiff") and Defendant Ford Motor Company ("Defendant") (collectively referred to as the "Parties") through their respective counsel hereby stipulate as follows:

WHEREAS, based on the Case Management Conference date, the current deadline to conduct a Rule 26(f) conference is February 1, 2016 and the deadline for the Parties to exchange Initial Disclosures and file a Joint Case Management Statement is currently February 12, 2016;

WHEREAS, on January 13, 2016, Defendant filed a Motion to Dismiss Amended Complaint (Dkt. No. 43) which is currently scheduled to be heard on February 22, 2016; and

WHEREAS, the Parties agree that in the interest of maximizing case efficiency, the deadlines for the 26(f) conference, Initial Disclosures and Joint Case Management Statement should follow after the February 22, 2016 hearing on Defendant's Motion to Dismiss;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND REQUESTED by and between the Parties, through their respective attorneys of record, that the Case Management Conference be continued to March 21, 2016 at 1:30 p.m., which would also extend the Parties' deadline to conduct a Rule 26(f) conference to February 29, 2016 and the Parties' deadline to exchange Initial Disclosures and file a Joint Case Management Statement to March 14, 2016.

ORDER

For good cause appearing therefor, and pursuant to the parties' stipulation, it is hereby ORDERED that the Case Management Conference be CONTINUED to March 21, 2016 at 1:30 p.m.

PURSUANT TO STIPULATION, IT IS SO ORDERED.