STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES

EDWARD M. CHEN, District Judge.

This Stipulation is entered into by and among Plaintiff Thomas R. Kelly ("Plaintiff") and Defendants E.S. West Coast, LLC dba Energy Systems and Worth Holdings, LLC (collectively referred to as "Defendants"), by and through their respective counsel.

WHEREAS, on November 20, 2017, the Court entered a Notice (Docket Number 28) continuing the Further Case Management Conference, initially set for December 7, 2017 to December 8, 2017 at 2:00 p.m. in Courtroom 5;

WHEREAS, pursuant to the foregoing Notice, a Joint Case Management Statement is currently due by December 1, 2017;

WHEREAS, Plaintiff's counsel, Michael G. Miller, has a scheduled deposition to commence on December 8, 2017 at 9:00 a.m. in Santa Rosa in another matter which cannot be rescheduled due to an upcoming trial date. The deposition will last at least six hours, which would not allow enough time for Mr. Miller to travel to San Francisco for the Further Case Management Conference on December 8, 2017;

WHEREAS, Mr. Miller and Defendants' counsel, Brandon Kahoush, are both available to attend a Further Case Management Conference on December 21, 2017 at 1:30 p.m. in Courtroom 5;

WHEREAS the parties agree that the continuance of the Case Management Conference and all related deadlines is necessary;

NOW, THEREFORE, pursuant to Local Rule 6-2(a), the Parties hereby stipulate and agree, through their respective counsel, as follows:

1. The December 8, 2017 Further Case Management Conference shall be taken off calendar and rescheduled to December 21, 2017 at 1:30 p.m., 10:30 a.m. or another date that is convenient to the Court.

2. The deadline to file the Joint Case Management Conference shall be continued to and including December 14, 2017.

IT IS SO STIPULATED

PURSUANT TO STIPULATION, IT IS SO ORDERED.

ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1

I, Michael G. Miller, attest that concurrence in the filing of this Stipulation to Continue the Case Management Conference and related deadlines has been obtained from the other signatory. I declare under penalty of perjury under the laws of the United States of America, that the foregoing is true and correct.

Executed this 27th day of November 2017 in Santa Rosa, California.