JOINT STIPULATION AND[PROPOSED] ORDER TO CONTINUE PLAINTIFF IRMA RAMIREZ'S CROSS-MOTION FOR SUMMARY JUDGMENT

WILLIAM ALSUP, District Judge.

Plaintiff Irma Ramirez ("Plaintiff") and Defendant Fulton Market Place S.C., LP ("Defendant") by and through their respective attorneys of record, stipulate as follows:

RECITALS

WHEREAS, Plaintiffs Cross-Motion for Summary Judgment ("Cross-Motion") is currently set for hearing on September 22, 2016;

WHEREAS, counsel for Defendant is on a pre-paid vacation to Hawaii from September 22, 2016 to September 30, 2016 and will be unable to attend the currently scheduled hearing for the Cross-Motion;

WHEREAS, Defendant's opposition was due on August 18 (14 days after filing ofMotion);

WHEREAS, Defendant's counsel's administrative assistant incorrectly used the Central District local rules to calendar the opposition for September 1, 2016 (21 days before the hearing), which mistake was not discovered by counsel until August 25, 2016, when the Court brought the issue to counsel's attention;

WHEREAS, Defendant did not timely file an opposition because of the incorrectly calendared due date;

WHEREAS, Plaintiff's reply was to be filed and served on August 25, 2016 (7 days after filing of the opposition);

WHEREAS, as a result of Defendant's counsel's vacation, Plaintiff and Defendant have agreed to continue the hearing on the Cross-Motion to October 13, 2016;

WHEREAS, in light of the continuance of the hearing on the Cross-Motion, Defendant's opposition to the Cross-Motion shall now be due on September 8, 2016; and

WHEREAS, in light of the continuance of the hearing on the Cross-Motion, Plaintiff's reply to the opposition to the Cross-Motion shall now be due on September 15, 2016.

It is now hereby stipulated by the Parties:

1. The hearing on Plaintiffs Cross-Motion for Summary Judgment is hereby continued, subject to the Court's calendar, to October 13, 2016, at 8:00 a.m.

2. Defendant's opposition shall be filed and served on September 8, 2016.

3. Plaintiff's reply shall be filed and served on September 15, 2016.

IT IS SO STIPULATED.

PROPOSEDORDER

In view of the parties' Stipulation, IT IS ORDERED that the hearing on Plaintiff's Cross-Motion for Summary Judgment is hereby continued to October 13, 2016, at 8:00 a.m. Defendant's opposition shall be filed and served on September 8, 2016, and Plaintiff's reply shall be filed and served on September 15, 2016.