WILLIAM ALSUP, District Judge.
Pursuant to Civil Local Rule 6-2(a), Defendants Joey C. Greenberg and Nicholas Claussen (collectively, the "Defendants") on the one hand, and Plaintiff Crop Production Services, Inc. ("Plaintiff"), on the other hand, by and through their respective counsel of record, hereby submit this Stipulated Request for Order Continuing the Date of the Initial Case Management Conference, currently set for October 13, 2016, to November 10, 2016, and state as follows:
WHEREAS, Plaintiff filed its initial Complaint in this matter on July 15, 2016;
WHEREAS, on July 19, 2016, prior to Defendants being served with the Complaint, the Court issued an initial Case Management Scheduling Order setting the initial Case Management Conference for October 13, 2016;
WHEREAS, Plaintiff filed its First Amended Complaint on August 1, 2016;
WHEREAS, Defendants were served with process in this matter on August 25, 2016;
WHEREAS, Lewis Warren and Michael Wanser of Abbey, Weitzenberg, Warren, & Emery, P.C., were retained in this matter by Defendants on or about September 14, 2016;
WHEREAS, as more fully discussed in the accompanying Declaration of Lewis Warren, Mr. Warren is lead trial counsel for the Defendants and will be out of the country on the date presently set for the initial Case Management Conference due to a long-standing vacation, which was scheduled long before the Defendants were served in this matter and long before Mr. Warren was retained as their counsel;
WHEREAS, Mr. Warren has a substantive hearing in a matter in Sonoma County Superior Court scheduled for the morning of November 3, 2016;
WHEREAS, on September 22, 2016, the parties met and conferred in accordance with FRCP Rule 26(f), and, during that conference, Defendants requested and Plaintiff consented to a continuance to November 10, 2016, for the initial Case Management Conference;
WHEREAS, the Parties have previously stipulated to a two-week extension of time for Defendants to respond to the First Amended Complaint [ECF No. 28] and, except for the foregoing, no other time modifications have been requested in this case; and
WHEREAS, the requested modification of the initial Case Management Conference date will also extend the date by which the parties must file the Joint Case Management Statement in accordance with FRCP Rule 26(f) and Northern District Local Rule 16-9 and, except for the foregoing, the requested modification will not materially affect the schedule in the instant case.
NOW THEREFORE, IT IS HEREBY STIPULATED by and between the parties, through their respective counsel, that the parties request the Court to enter an Order changing the date of the Initial Case Management Conference from October 13, 2016, to November 10, 2016.
Pursuant to stipulation, and for good cause shown, the initial Case Management Conference and all associated deadlines shall be continued to November 10, 2016 at 11:00 a.m. in Courtroom 8, 19th Floor, San Francisco, California.