STIPULATION AND [PROPOSED] ORDER TO CONTINUE CERTAIN PRETRIAL DATES IN LIGHT OF NOTICE OF SETTLEMENT CONFERENCE AND SETTLEMENT CONFERENCE ORDER

EDWARD M. CHEN, District Judge.

WHEREAS the parties to this litigation have been working diligently and cooperatively to accomplish the multitude of pretrial tasks as set forth in the First Amended Case Management and Pretrial Order for Jury Trial (ECF No. 146) as modified by subsequent stipulations and orders extending certain of the deadlines (ECF Nos. 178, 219);

WHEREAS on June 7, 2016, the Court ordered the parties to participate in a settlement conference with Chief Magistrate Judge Spero on June 13, 2016 beginning at 9:30 a.m.; and

WHEREAS by its Notice of Settlement Conference and Settlement Conference Order (ECF No. 231) (the "Settlement Conference Order") Chief Magistrate Judge Spero has ordered all parties and lead trial counsel to appear at the June 13 settlement conference and the parties to submit Settlement Conference Statements by 12:30 p.m. on June 10, 2016; and

WHEREAS to allow for the parties to comply with the order for the settlement conference so that a meaningful settlement conference may be conducted they will be required to spend significant time between the date and time of this Stipulation and the settlement conference to prepare their submissions to the Chief Magistrate Judge, to consult with their respective clients concerning the matters required to be addressed by the parties in response to the Settlement Conference Order from Magistrate Judge Spero and otherwise prepare for the settlement conference, and for certain of the required participants to travel from out of state to participate in the settlement conference; and

WHEREAS the parties believe that the time required to prepare for and participate in the settlement conference will make it difficult for them to complete certain pretrial tasks in the timeframes previously ordered by the Court; and

WHEREAS the parties have met and conferred regarding the foregoing and agree that under the circumstances there is good cause to request a short extension of certain of the pretrial deadlines in light of the developments associated with the court-ordered settlement conference, so that the parties can focus on settlement efforts over the next several days; and

WHEREAS the parties are not requesting any continuance of the August 15, 2016 trial date or July 19, 2016 pre-trial conference set forth in the Court's October 19, 2015 First Amended Case Management and Pretrial Order (ECF No. 146);

THEREFORE, good cause existing, IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto, through their counsel of record, that they jointly request a modification of certain pretrial deadlines, and respectfully request the Court to adopt the following new deadlines:

1. The Parties respectfully request that the deadline for completion of expert discovery be extended from June 24, 2016 to July 1, 2016;

2. The Parties respectfully request that the deadline for the filing of motions in limine be extended from June 17, 2016 to June 21, 2016;

3. The Parties respectfully request that the deadline to oppose motions in limine be extended from June 24, 2016 to June 28, 2016; and

4. The Parties respectfully request that the deadline to submit the pretrial conference statement and related documents be extended from June 28, 2016 to July 5, 2016.

I attest that I have obtained Mr. Johnson's, Mr. Huss's, and Mr. Sandler's concurrence in the filing of this document.

IT IS SO ORDERED.