[Removed from Contra Costa County Superior Court, Civil Case No.C16-00131]

STIPULATION AND [PROPOSED] ORDER TO CHANGE DEADLINE TO FILE JOINT CASE MANAGEMENT CONFERENCE STATEMENT

[Local Rule 6-2]

SAUNDRA B. ARMSTRONG, District Judge.

STIPULATION

Pursuant to Local Rule 6-2, the parties hereby submit this Stipulation and [Proposed] Order to change the deadline in which to file the Joint Case Management Statement of Plaintiff Gary Ferras ("Plaintiff") and Defendant Husqvarna Construction Products North America, Inc. ("Defendant"). The initial case management conference in this action is currently scheduled for June 1, 2016, at 2:30 p.m., and the deadline for the parties to file a joint case management statement is May 25, 2016.

WHEREAS, the parties have been meeting and conferring to finalize a written joint case management statement to submit to the Court.

WHEREAS, on May 25, 2016, Plaintiff Gary Ferras' counsel, Mr. Alan Cohen, suffered a medical emergency;

WHEREAS, Mr. Cohen has requested and, counsel for Defendant agrees, that to allow Mr. Cohen to attend to his medical emergency and sufficient time to review the joint case management statement the parties have been working on, the deadline to file the parties' Joint Case Management Statement should be extended by two days to May 27, 2016.

NOW, THEREFORE, THE PARTIES AGREE AS FOLLOWS:

SO STIPULATED.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

The Court, having read and considered the parties' Stipulation to Change Deadline To File Joint Case Management Conference Statement, and finding good cause in support thereof, hereby orders that the deadline for the parties to file their joint case management conference statement is extended as by two days to May 27, 2016.