STIPULATION TO EXTEND DATES SET FORTH IN THE COURT'S SCHEDULING ORDER; [PROPOSED] ORDER AS MODIFIED BY THE COURT

RICHARD SEEBORG, District Judge.

STIPULATION

Plaintiff Susan Mullin ("Plaintiff") and Defendant American Income Life Insurance Company ("AIL") (collectively "Parties"), by and through their respective counsel of record, hereby stipulate as follows:

WHEREAS, the dispositive motion hearing cutoff is currently May 9, 2019, the pretrial conference is set for June 26, 2019 and trial is set for July 8, 2019; and

WHEREAS, the parties have completed discovery with the exception of a deposition to be taken in Texas, which was previously scheduled but continued by counsel for both parties due to a calendar conflict; and

WHEREAS, the parties have commenced settlement discussions and wish to continue those discussions, possibly in the context of a mediation session, without the need to file dispositive motions in time to comply with the May 9, 2019 motion hearing cutoff, and without the need to conduct the remaining deposition in Texas;

NOW THEREFORE THE PARTIES HEREBY STIPULATE AS FOLLOWS:

The parties agree to request that the Court amend the Scheduling Order to permit the taking of the Texas deposition not later than May 24, 2019, and to extend the dispositive motion hearing cutoff date to June 27, 2019; and, the parties agree to request that the Court continue the pretrial conference to August 14, 2019 and the trial to August 26, 2019, or such dates as are convenient with the Court's calendar.

IT IS SO STIPULATED.

Filer's attestation: Pursuant to Civil Local Rule 5-1(i)(3) regarding signatures, Royal F. Oakes hereby attests that concurrence in the filing of this document and its contents has been obtained by all signatories listed.

[PROPOSED] ORDER

Having reviewed the Parties' Stipulation to Extend the Dates Set Forth in the Court's Scheduling Order, and for good cause shown, IT IS HEREBY ORDERED THAT:

• The Scheduling Order is amended to reflect a deadline to conduct the Texas deposition ofby May 24, 2019 [proposed May 24, 2019].

• The Scheduling Order is amended to reflect a dispositive motion hearing cutoff date of June 27, 2019 [proposed June 27, 2019].

• The Scheduling Order is amended to reflect a pretrial conference date of August 14, 2019 [proposed August 14, 2019].

• The Scheduling Order is amended to reflect a trial date of August 26, 2019 [proposed August 26, 2019].

IT IS SO ORDERED.