STIPULATION AND [PROPOSED] ORDER TO EXTEND ADR DEADLINE

JON S. TIGAR, District Judge.

Defendants Trans Union, LLC ("Trans Union"), Experian Information Solutions, Inc. ("Experian"), Equifax Information Services, LLC ("Equifax"), Capital One Bank (USA), N.A. ("Capital One"), erroneously sued as Capital One Financial Corporation, and Plaintiff (collectively, the "Parties"), by their respective counsel, hereby stipulate and respectfully request that the Court extend the alternative dispute resolution ("ADR") deadline by 60 days. In support of this Stipulation, the Parties state:

1. This case was filed on January 19, 2017. See Doc. No. 1.

2. Pursuant to the Court's Order Selecting ADR Process [Doc. No. 35], the Parties are to complete ADR by June 28, 2017.

3. The Parties state that good cause exists to extend the deadline to complete ADR as there has not yet been a Case Management Conference, the Parties are in the early stages of discovery and are continuing to collect information relevant to the case, the Parties are engaging in ongoing settlement discussions, and the Parties have thus far been unable to identify a mediation date on which all Parties and the mediator are available.

4. The Parties request that the Court extend the ADR deadline by 60 days so that they may have more time to engage in direct settlement negotiations and conduct necessary discovery before completing ADR.

5. This is the first extension requested by any party.

WHEREFORE the Parties respectfully request that the Court extend the deadline to complete ADR by 60 days.

PURSUANT TO STIPULATION, IT IS SO ORDERED that the Parties' deadline to complete ADR is hereby extended by 60 days.