STIPULATED REQUEST TO CONTINUE MEDIATION DEADLINE AND [PROPOSED] ORDER

JON S. TIGAR, District Judge.

Plaintiffs GLORIA YOUNG and MARGARET CEPHAS-GROSS (collectively, "Plaintiffs"), and Defendants HOLLAND AMERICA LINE, N.V., CARNIVAL CORPORATION dba CARNIVAL CRUISE LINES and CWC TRAVEL, INC. dba COSTCO TRAVEL (collectively, "Defendants"), by and through their respective counsel, hereby stipulate as follows pursuant to Civil L.R. 6-2:

1. By court order, the deadline to complete private mediation is currently set for July 5, 2017 and the deadline to file a joint mediation statement is set for July 12, 2017 [Dkt. No. 57];

2. The parties have scheduled private mediation with mediator Harris E. Weinberg of Harris E. Weinberg Mediation on September 11, 2017;

3. Due to scheduling conflicts between the parties, their respective counsel, and the agreed-upon mediator, September 11, 2017 is the earliest date that the parties are able to complete private mediation;

4. The parties and their respective counsel agree that this request for continuance does not result from any lack of diligence on the parties' or counsels' parts;

5. Pursuant to Civil L.R. 6-2(a)(2), the parties hereby disclose the following previous time modifications in this case: By stipulation, the parties agreed to extend the time for Defendants to answer Plaintiffs' Complaint from January 11, 2017 to January 25, 2017 [Dkt. No. 53];

6. Pursuant to Civil L.R. 6-2(a)(3), the parties note that the deadline for expert disclosures is currently set for September 1, 2017 and the deadline for expert rebuttals is set for September 28, 2017;

7. The parties agree that in light of the scheduled mediation, and to conserve litigation fees and costs, good cause also exists for a short continuance of the current expert disclosure and rebuttal deadlines;

8. Based on the foregoing, the parties respectfully request that the Court continue the deadline to complete private mediation to September 13, 2017 in order to account for the possibility of a multi-day mediation, and continue the deadline to file a joint mediation statement to September 20, 2017; and

9. The parties respectfully request that the Court also continue the deadline for expert disclosures and expert rebuttals to September 27, 2017 and October 24, 2017, respectively, or to dates agreeable to the Court.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.