STIPULATION TO CONTINUE ALL DATES & STAY MATTER PENDING APPROVAL OF SETTLEMENT and PROPOSED ORDER

WILLIAM H. ORRICK, III, District Judge.

This stipulation seeking a continuance of the trial date and all other dates ("Stipulation") is entered into by and between Plaintiff Tonie Harris ("Plaintiff") and Defendants United Airlines, Inc. and Rossi Thomas ("Defendants"), (collectively, the "Parties"). By and through their respective counsel, the Parties jointly request that the Court continue the October 10, 2017, trial date, and all other dates currently set in this matter, by at least 90 days, based on the following:

1. Plaintiff filed her Second Amended Complaint in this matter on December 11, 2015 ("Lawsuit").

2. Plaintiff has a parallel Workers' Compensation matter pending before the California Workers' Compensation Appeals Board ("WCAB"), Case No. ADJ9378869 ("Workers' Comp Claim").

3. A settlement conference was held before Magistrate Judge Donna M. Ryu on February 3, 2017, at which the Parties reached agreement to settle both the Lawsuit and the Workers' Comp Claim.

4. Because Plaintiff is entitled to Medicare benefits, the settlement of the Workers' Comp Claim must be approved both by Medicare and then by the WCAB.

5. It is estimated that the above-described approval process will take between 60 and 90 days.

6. The Parties wish to avoid incurring the expense of discovery and preparing for a trial when the matter has been settled contingent only on the above-described approvals.

7. The trial date has not been previously continued, and the Parties have not previously requested from the Court any continuance in the Lawsuit.

8. In view of the foregoing, the Parties conclude that good cause exists for a continuance of the trial date to January 9, 2018, or a date thereafter convenient for the Court, and a like continuance of 90 days for all other dates, as outlined below.

IT IS THEREFORE STIPULATED AND AGREED by and among the Parties through their respective counsel of record, that:

1. The trial date currently scheduled on October 10, 2017, be continued to on or after January 9, 2018.

2. The Expert Disclosure Date currently set for March 7, 2017, be continued to on or after June 6, 2017.

3. The Expert Rebuttal Date currently set for April 6, 2017, be continued to on or after July 6, 2017.

4. The Fact Discovery Cutoff currently set for April 17, 2017, be continued to on or after July 17, 2017.

5. That the Expert Discovery Cutoff currently set for May 7, 2017, be continued toon or after August 7, 2017.

6. That the Dispositive Motions Heard By currently set for July 19, 2017, be continued to on or after October 18, 2017.

7. That the Pretrial Conference currently set for September 18, 2017, be continued to on or after December 18, 2017.

8. That the Lawsuit in all respects be STAYED for 90 days.

Signature Attestation Pursuant to LCR 5-1(i)(3)

I, Judith Droz Keyes, obtained permission from opposing counsel to electronically sign the Stipulation to Continue All Dates & Stay Matter Pending Approval of Settlement on their behalf on February 7, 2016

ORDER

The above STIPULATION TO CONTINUE ALL DATES & STAY MATTER PENDING APPROVAL OF SETTLEMENT is approved. As of the date of this Order, the matter is stayed for 90 days. Further, the Court orders the following dates in this matter:

IT IS SO ORDERED.