STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT AND RULE 26(F) REPORTS AND CONFERENCE

DONNA M. RYU, Magistrate Judge.

STIPULATION

Pursuant to Local Rule 6-1(a), the parties hereby stipulate to the following:

WHEREAS, plaintiff Felicia Dillion's and defendant BET Information Systems, Inc., doing business as Survey.com,'s respective counsel have met and conferred regarding Defendant's intended response to the Complaint;

WHEREAS, Plaintiff indicated that she intends to file an amended complaint on October 22, 2018;

WHEREAS, Defendant intends to respond to the pending Complaint with a Motion to Compel Arbitration;

WHEREAS, the parties are discussing the possibility of arbitrating this dispute and believe it is in all parties' interest for Defendant to wait to respond to any amended complaint that may be filed;

WHEREAS, the parties agree that the deadline to submit a Rule 26(f) report and the initial Case Management Conference shall be extended in light of the parties' discussions;

Accordingly, IT IS HEREBY STIPULATED AND AGREED that:

1. If Plaintiff elects to amend the complaint, Plaintiff shall do so no later than October 22, 2018;

2. Defendant's deadline to respond to the operative complaint shall be the later of 14 days after Plaintiff files any amended Complaint or November 5, 2018.

3. The last day to file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report and file Case Management Statement per Standing Order re Contents of Joint Case Management Statement shall be extended from October 31, 2018 to November 21, 2018; and

4. The Initial Case Management Conference shall be extended from November 7, 2018 to November 28, 2018.

SIGNATURE CERTIFICATION

I hereby certify that the content of this document is acceptable to Trenton R. Kashima, counsel for Plaintiff, and I have obtained his authorization to affix his electronic signature to this document.

[PROPOSED] ORDER

Plaintiff and Defendant's counsel have requested to extend the time to file Rule 26(f) Reports and reschedule the Initial Case Management Conference. Good cause appearing, their Stipulation is granted.

The last day to file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report and file Case Management Statement per Standing Order re Contents of Joint Case Management Statement shall be extended November 28, 2018.

The Initial Case Management Conference shall be rescheduled to November 28, 2018. 5, 2018 at 1:30 p.m.December

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.