JOSEPH C. SPERO, District Judge.
Pursuant to Civil Local Rule 6-1(a), Plaintiff, Seton Medical Center ("Plaintiff"), and Defendant Blue Cross and Blue Shield of North Carolina ("BCBSNC"), by and through their respective counsel of record, hereby submit this stipulation based on the following:
BCBSNC removed this civil action, Case No. CIV536368, from the Superior Court of the State of California, for the County of San Mateo, to the United States District Court, for the Northern District of California, based upon diversity on December 29, 2015;
A responsive pleading to the Complaint was originally due to be filed and served on behalf of BCBSNC on or before January 5, 2016;
The parties stipulated to, and the Court granted, an extension of time of an additional 27 days to and including February 1, 2016 for BCBSNC to answer, move or otherwise respond to the Complaint;
The parties subsequently stipulated to, and the Court granted, an extension of time of an additional 30 days to and including March 1, 2016 for BCBSNC to answer, move or otherwise respond to the Complaint;
The parties are engaged in settlement negotiations and in order to facilitate further settlement discussions, BCBSNC has requested and Plaintiff has agreed to an additional 15 days to and including March 15, 2016 for BCBSNC to answer, move or otherwise respond to the Complaint;
The next Court ordered deadline is on March 11, 2016 for the parties to meet and confer re initial disclosures and early settlement. An additional 15 days for BCBSNC to answer or respond to Plaintiff's Complaint will not alter the date of any event or any deadline already fixed by Court order, as the parties will meet and confer notwithstanding any extension to respond to the Complaint;
Therefore, IT IS HEREBY STIPULATED by and between Plaintiff and BCBSNC, by and through their respective attorneys of record, that BCBSNC shall have until on or before March 15, 2016 to answer, move or otherwise respond to Plaintiff's Complaint.