STIPULATION AND ORDER TO EXTEND TIME FOR ALLY FINANCIAL INC. TO FILE ITS REPLY IN SUPPORT OF ITS MOTION TO DISMISS THE CROSS CLAIMS OF DEFENDANT HANLEES FREMONT, INC., PURSUANT TO LOCAL RULE 6-1(b)

HAYWOOD S. GILLIAN, Jr., District Judge.

Pursuant to Local Rule 6-1(b), Defendant Hanlees Fremont, Inc. ("Hanlees") and Defendant Ally Financial Inc. ("Ally") (together, the "Parties') by and through their respective counsel of record, hereby stipulate as follows:

STIPULATION

WHEREAS, Hanlees filed cross claims against Ally in connection with its answer to Plaintiff Weerachai Chaiwong's complaint on September 26, 2016 (see Dkt. No. 25);

WHEREAS, the parties previously stipulated to an extension of Ally's deadline to file its response to Hanlees' cross claims on October 13, 2016 (See Dkt. no. 32);

WHEREAS, Ally filed a motion to dismiss Hanlees' cross claims on November 7, 2016 that is set to be heard on January 26, 2017;

WHEREAS, the parties previously stipulated to two extensions for Hanlees to file its opposition to Ally's motion to dismiss and to two extensions for Ally to file its reply thereto;

WHEREAS, the first stipulated request for an extension of both deadlines was made on November 21, 2016. (See Dkt. No. 37.) The request was refiled on December 2, 2016 after notice from the court of an electronic filing error. (See Dkt. No. 38.) The Court retroactively granted this request on December 7, 2016, and set Hanlees' opposition deadline as December 5, 2016 and Ally's reply deadline as December 19, 2016. (See Dkt. No. 41.);

WHEREAS, the second stipulated request for an extension of both deadlines was made on December 5, 2016. (See Dkt. No. 39.) The Court granted this request on December 7, 2016, and set Hanlees' opposition deadline as December 19, 2016 and Ally's reply deadline as January 7, 2017. (See Dkt. No. 42.);

WHEREAS, Hanlees filed its opposition to Ally's motion to dismiss on December 19, 2016 (See Dkt. No. 46);

WHEREAS, Ally's reply brief in support of its motion to dismiss Hanlees' cross claims is currently due on January 7, 2017;

WHEREAS, Hanlees has agreed to an extension of Ally's time to file its reply brief by ten (10) days or until January 17, 2017 to accommodate Ally's counsel's trial and holiday vacation schedule (see Kamka Decl. in support of stipulation, ¶¶ 1-2);

WHEREAS, this extension will not have any effect on the current schedule for the case.

IT IS HEREBY STIPULATED TO, by and between the Parties herein, through their respective attorneys of record, that Ally will have a ten (10) day extension, up to and including January 17, 2017, in which to file and serve its reply in support of its motion to dismiss Hanlees' cross claims.

This Stipulation is made without prejudice to, or waiver of, any rights or defenses otherwise available to the Parties in this action.

I, Mary Kate Kamka, am the ECF user whose identification and password are being used to file this Stipulation and [Proposed] Order to Extend Time. I hereby attest that Martin Putnam has concurred in this filing.

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.