HAYWOOD S. GILLIAM, Jr., District Judge.
Pursuant to Civil Local Rule 6-2, the parties hereby submit their stipulated request to extend time for service and for Defendants' time to answer, and to move the Case Management Conference currently scheduled for May 10, 2016, at 2:00 p.m., for the following reasons:
1. This action is one of two cases filed in the above-captioned court, that involve all or a material part of the same subject matter and all, or substantially all, of the same parties as this action. The two matters have since been determined related, and are now both assigned to Hon. Haywood S. Gilliam, Jr. This stipulated request is being simultaneously made in the other case as well (
2. In both actions, Wil Fong, Deputy Attorney General, has accepted service on behalf of the state defendant, California Highway Patrol, via a waiver of service executed on January 12, 2016.
3. The parties have conferred and share a good faith interest in an efficient and economical approach to managing these litigations. To that end, both matters are now currently scheduled for a global private mediation on May 2, 2016, in San Francisco, California, with Hon. Joseph W. Hilberman of ADR Services, Inc.
4. As such, the parties agree that moving the Case Management Conference set for May 10, 2016, and extending Defendants' time to be served, appear and respond to the Complaint, will allow sufficient time for the parties to prepare for, participate in, and complete the privately scheduled mediation in advance of appearing in court.
5. Therefore, the parties stipulate and jointly request that new dates in this matter be assigned and ordered as follows:
6. There has been one previous request and order for time modification in the case. However, the instant requested extension of time will not appreciably further delay proceedings in this action, and will enable more efficient and economical management of the litigation by allowing time for participation and completion of a private global mediation in advance of any court appearance. No parties will be prejudiced, and all parties will remain similarly positioned to proceed without further delay.