STIPULATION TO POSTPONE JULY 5, 2016 FILING AND JULY 7, 2016 STATUS HEARING

CAM FERENBACH, Magistrate Judge.

At the May 18, 2016 Court hearing on various motions, the Court issued certain rulings, directed counsel for the respective parties to meet, attempt to work or at least narrow disputed discovery issues, and the to file concise statements of remaining issues by 12:00 p.m. on July 5, 2016. The Court then set a status conference on July 7, 2016. (ECF No. 86, issued on May 19, 2016.)

Thereafter, and in the meantime, Defendant BANK OF AMERICA, N.A. ("BANA"), responded to then pending discovery requests by Plaintiff. On June 5, 2016, Plaintiff postponed the previously subpoenaed Rule 30(b)(6) deposition of BANA (regarding Subject No. 6). On June 6, 2016, BANA requested Plaintiff's available dates to conduct the Rule 30(b)(6) deposition(s) of BANA (pursuant to the category and time limitations imposed by the Court in its May 18, 2016 ruling), but Plaintiff has not provided available dates since that time. On June 22, 2016, BANA took the deposition of Plaintiff's current employer, Geoffrey Baughman, also in accord with the Court's rulings on May 18, 2016.

Plaintiff's undersigned lead counsel was unable to actively participate in all of the other expected meet and confer and discovery dispute resolution activities during the month of June 2016, due to a knee injury she sustained on June 3, 2016, and the subsequent medical treatment in the following week and which is continuing. Additionally, most of Plaintiff's undersigned counsel's available time in June was required to participate in the final discovery activities in Roberts v. Clark County School District, U.S. District Court Case No. 2:15-dv-00388, which included moving and the taking of numerous depositions of CCSD school officials, which were postponed and moved due to Ms. England's injury. Additionally, the Court set final supplemental briefing for the cross-motions for summary judgment, which itself was extended from June 30, 2016 to July 14, 2016 to accommodate Ms. England's injury and unavailability, as she is lead counsel and was the attorney prepared to take these depositions, the last of which will take place on June 30, 2016. (See, Roberts v. CCSD, ECF. Nos.132, 133, 134 and 135.) In addition to medical appointments on July 5, 2016, due to the sale of her office building by the existing landlord, Ms. England is moving her office and physical location during the week of July 6-8, 2016.

In light of these unexpected and unavoidable time constraints, undersigned Plaintiff's counsel asked counsel for BANA to join her in this request to allow the parties additional time to meet and confer on numerous discovery matters, to request that the filing of the concise statement of remaining discovery issues be postponed to July 21, 2016 or later, and for the status conference to be continued as soon as practically possible thereafter (preferably July 25 or 26). For these and other good and just cause,

IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ALEXIS GURSHIN, through her attorney, Kathleen J. England of England Law Office, and Defendant BANK OF AMERICA, N.A., through its attorneys, Bethany A. Pelliconi and Lindsay L. Ryan of McGuireWoods LLP, to request that the filing of the concise statement of remaining discovery issues be postponed to July 21, 2016 or later, and for the status conference to be continued as soon as practically possible thereafter (preferably July 25 or 26) at the Court's convenience.

IT IS SO ORDERED.

IT IS HEREBY ORDERED that a status hearing is scheduled for 3:00 p.m., July 26, 2016, in courtroom 3D.