STIPULATION TO VACATE TRIAL DATE AND CONTINUE APRIL 1, 2016 CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

JON S. TIGAR, District Judge.

Plaintiff Ruben J. Ruiz ("Plaintiff") and defendants M. Sawaya, N. Daharsh, and J. Shaw ("Defendants") enter the following stipulation:

WHEREAS the parties have settled this case in principle and are finalizing the settlement papers;

WHEREAS trial is presently scheduled for April 25, 2016;

WHEREAS the Court has scheduled a case management conference on April 1, 2016 at 2:00 p.m., pursuant to order dated March 24, 2016 (ECF no. 132);

WHEREAS the parties anticipate finalizing the settlement papers and filing a joint stipulation to dismiss the case no later than April 14, 2016; and

WHEREAS counsel for Plaintiff additionally has a scheduling conflict on April 1, 2016, due to a deposition that he has committed to attend;

NOW, THEREFORE, Plaintiff and Defendants agree to ask the Court to vacate the trial date of April 25, 2016 and to continue the April 1, 2016 case management conference to April 15, 2016 or later to allow the parties time to finalize the settlement and dismiss the case. In the alternative, the parties agree that, with Court approval, Plaintiff's counsel may attend the case management conference on April 1, 2016 by telephone.

Attestation Under N.D. Cal. Civil Local Rule 5-1(i)

I, Robert B. Mullen, attest and declare as follows:

Concurrence in the filing of this document has been obtained from all signatories, and shall serve in lieu of their signatures on the document.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Signed on March 31, 2016 in San Francisco, California.

[PROPOSED] ORDER

The Court, having considered the above stipulation by the parties, hereby vacates the trial date of April 25, 2016 and continues the Case Management Conference presently scheduled for April 1, 2016 to April 15, 2016 at 2:00 p.m..

[In the alternative, the Court will allow counsel for plaintiff Ruben Ruiz to attend the Case Management Conference on April 1, 2016 by telephone.]