STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE

[Civil L.R. 6-2, 7-12, 16-2(e)]

THELTON E. HENDERSON, District Judge.

STIPULATION

Pursuant to Civil Local Rules 6-2, 7-12 and 16-2(e), and the Honorable Judge Thelton E. Henderson's civil standing order, Plaintiff DAVID COOK, by and through his attorney of record, David E. Castro of the Law Offices of Stawicki & Maples, and Defendant COUNTY OF CONTRA COSTA, by and through its attorney of record, Deputy County Counsel Nima E. Sohi of the Contra Costa County Counsel's Office, hereby stipulate that the initial case management conference ("CMC"), currently scheduled for February 8, 2016, at 1:30 p.m., be continued and rescheduled to April 11, 2016, at 1:30 p.m., or to another date more convenient for the Court.

Good cause exists to continue the date of the initial CMC, and associated deadlines (except initial disclosures), including preparing the Joint CMC Statement and Proposed Order per Civil Local Rule 16-9, because Plaintiff DAVID COOK filed a Second Amended Complaint ("SAC") on January 9, 2016, named new defendants in the SAC who have not been served nor appeared in this action, and Defendant COUNTY OF CONTRA COSTA has filed a motion to dismiss the SAC. The hearing on the County's pending motion is scheduled for March 7, 2016.

This continuance will provide sufficient time after the pending motion to dismiss is heard for the parties to meet and confer with respect to the contents of the Joint CMC Statement, and to prepare the statement for the Court. There have been no prior time modifications requested or ordered by the Court.

SO STIPULATED.

[PROPOSED] ORDER

Having considered the stipulation filed by the parties, and good cause appearing, the Court hereby ORDERS that the initial Case Management Conference be continued to April 11, 2016 at 1:30 p.m., with the associated deadlines continued accordingly.

PURSUANT TO STIPULATION, IT IS SO ORDERED.