JOINT STIPULATION AND AMENDED [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND EXTENDING RULE 26(F) REPORT, INITIAL DISCLOSURES, AND CASE MANAGEMENT STATEMENT FILING DEADLINES

MARIA-ELENA JAMES, Magistrate Judge.

WHEREAS, Plaintiff JOSE GONZALEZ ("Plaintiff") filed a First Amended Complaint ("Complaint") against Defendants FALLANGHINA, LLC DBA PAISAN OSTERIA, LONGBRANCH BERKELEY LLC, HAL BRANDEL, AND WALTER WRIGHT (collectively "Defendants") in the Northern District of California on May 31, 2016;

WHEREAS, on April 11, 2016, Judge Maria-Elena James issued an Order Setting Initial Case Management Conference and ADR Deadlines;

WHEREAS, on May 17, 2016, attorneys Garry Mathiason, Kai-Ching Cha and Danton Liang filed their respective Notices of Appearance in this litigation (Doc No. 12, 16, 17), and attorney Scott R. Dallas filed a Notice of Change of Counsel, withdrawing as attorney of record for Defendants (Doc. No. 19).

WHEREAS, Judge James scheduled the Initial Case Management Conference to be heard on July 7, 2016 at 10:00 a.m.;

WHEREAS, Judge James set the last day to file a Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report, and file a Joint Case Management Statement on June 30, 2016;

WHEREAS, attorney Kai-Ching Cha, who will be the primary shareholder representing Defendants in this litigation, is not available for the Initial Case Management Conference on July 17, 2016 due to out of state travel from July 5, to July 15, 2016;

WHEREAS, the parties have agreed to request that the Initial Case Management Conference be continued to July 21, 2016;

WHEREAS, the parties also seek to extend the filing deadlines for the Rule 26(f) Report, initial disclosures, and Joint Case Management Statement to July 14, 2016;

WHEREAS, the parties' request is not made for the purpose of delay or any other improper purpose.

THEREFORE, in light of the parties' agreement to reschedule the Initial Case Management Conference and extend the related deadlines and in an effort to minimize costs, the parties stipulate and agree as follows:

1. The parties' July 7, 2016 Initial Case Management Conference shall be continued to July 21, 2016;

2. The parties will file the Rule 26(f) Report and Joint Case Management Statement and exchange initial disclosures on or before July 14, 2016.

IT IS SO STIPULATED.

AMENDED ORDER

Based upon the joint stipulation of both parties in the above-captioned case, and good cause appearing, it is hereby ordered that the parties' July 7, 2016 Initial Case Management Conference shall be continued to July 28, 2016. It is also hereby ordered that the parties' deadline of June 30, 2016 to file a Rule 26(f) Report and Joint Case Management Statement and exchange initial disclosures be extended to July 14, 2016. A joint case management statement shall be filed by July 21, 2016.

IT IS SO ORDERED.