STIPULATED REQUEST FOR ORDER EXTENDING TIME FOR HANLEES FREMONT, INC. TO RESPOND TO ALLY FINANCIAL'S MOTION TO DISMISS AMENDED CROSS-CLAIM, AND FOR ALLY TO FILE ITS REPLY, PURSUANT TO LOCAL RULE 6-2

HAYWOOD S. GILLIAM, JR., District Judge.

Pursuant to Local Rule 6-2, defendant and cross-complainant Hanlees Fremont, Inc. ("Hanlees"), defendant Ally Financial Inc. ("Ally"), and Plaintiff Weerachai Chaiwong (together, the "Parties"), by and through their respective counsel of record, hereby stipulate as follows:

STIPULATION

WHEREAS, Hanlees filed an answer to plaintiff's second amended complaint and a first amended cross-claim against Ally on October 27, 2017;

WHEREAS, Hanlees stipulated to a 17-day extension of time for Ally to respond to the amended cross-claim, from November 10, 2017 to November 27, 2017;

WHEREAS, Ally filed a motion to dismiss the amended cross-claim on November 27, 2017;

WHEREAS, Hanlees' opposition to Ally's Motion to Dismiss is presently due to be filed on December 11, 2017;

WHEREAS, counsel for Hanlees is engaged in a hearing on the merits of another case now before the American Arbitration Association, Gless v. Zoom, that has been extended to December 11, 2017;

WHEREAS, the parties have stipulated to an extension of time for Hanlees to file such opposition up to and including December 22, 2017;

WHEREAS, the extension on the deadline for Hanlees to file its opposition would make Ally's reply due on December 29, 2017;

WHEREAS, Ally's counsel has scheduling conflicts the week of December 25, 2017, and the parties have stipulated that Ally may have an extension of time to file its reply to and including January 4, 2018; and

WHEREAS, these extensions will not have any effect on the current schedule for the case.

IT IS HEREBY STIPULATED, by and between the Parties hereto, through their respective attorneys of record, to an order granting Hanlees an 11-day extension, up to and including December 22, 2017, in which to file a response to Ally's Motion to Dismiss the amended cross-claim. IT IS FURTHER STIPULATED that Ally may have an extension on its deadline to file its reply to January 4, 2018.

This Stipulation requests the first extension of time for Hanlees to respond to Ally's motion to dismiss the amended cross-claim and for Ally to file its reply in support of the motion to dismiss, and is made without prejudice to, or waiver of, any rights or defenses otherwise available to the Parties in this action.

PURSUANT TO STIPULATION, IT IS SO ORDERED.