WILLIAM H. ORRICK, District Judge.
Pursuant to Federal Rule of Civil Procedure 6(b) and Local Rules 6-1(b) and 6-2, Defendants INDIAN INSTITUTE OF TECHNOLOGY KHARAGPUR ("IIT"), through their undersigned counsel, hereby file the following request to postpone the Case Management Conference scheduled for April 11, 2017 at 2:00 p.m. for twenty four (24) days until May 5, 2017 at 2:00 p.m., or the Court's earliest available date thereafter. In support of this request, the Defendants submit as follows:
WHEREAS, on March 23, 2017, the Court issued an order scheduling a case management conference for April 11, 2017 at 2:00 p.m. (Dkt. 508);
WHEREAS, in February 2017, Defendant's counsel changed law firms and is currently seeking to obtain the files from the case from the previous firm. Defendant requires additional time to prepare for the Case Management Conference in order to adequately review and transfer all records that exist in the case, as well as to meet and confer on Case Management issues. An additional twenty four (24) days should permit sufficient time for the parties to attend to these matters;
WHEREAS, on February 22, 2017, Defendant filed a change of counsel, and therefore believes rescheduling the case management conference is appropriate. Defendant requires additional time to prepare for the Case Management Conference in order to adequately review all records that exist in the case. This will permit Defendant to meaningfully participate in the Case Management Conference. The parties require additional time for counsel to meet and confer to prepare a joint case management statement;
WHEREAS, counsel for Defendant is unavailable during the currently scheduled case management conference date of April 11, 2017;
WHEREAS, rescheduling this Case Management Conference will allow both parties additional time to meaningfully meet and confer regarding case management issues and Plaintiffs' counsel has indicated they are not opposed to the rescheduling of the Case Management Conference or to an extension of time for submission of a joint case management statement;
WHEREAS, no Party will be prejudiced by the relief requested in the stipulation and there will be no changes to the case schedule in existence prior to the entry of this stipulation; and
WHEREAS, all Parties' claims and defenses are expressly preserved and not waived by entering into this stipulation.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, between the Parties and Defendant respectfully moves the Court that the Case Management Conference shall be moved from April 11, 2017 at 2:00 p.m. to May 5, 2017 at 2:00 p.m., or the soonest date thereafter that the Court is available, and that the date for the submission of the joint case management statement will be moved from April 4, 2017 to April 28, 2017.