PEGGY A. LEEN, Magistrate Judge.
Plaintiff Viaggio Vita LLC ("Viaggio"), by and through its counsel of record, the law firm of Gibson Lowry LLP, and Defendants Bruce Goold ("Mr. Good"), Island Flavor Café, LLC ("IF-California") and Island Flavor, LLC ("IF-Nevada") (collectively "defendants"), by and through their counsel of record, Marquis Aurbach Coffing and the Law Offices of Philip A. Kantor, P.C., hereby stipulate and agree as follows:
1. On October 12, 2018, Viaggio filed a complaint against defendants [ECF No. 1];
2. Defendants' current deadlines to respond to the complaint are November 9, 2018, and November 12, 2018;
3. This is the first stipulation for an extension of time to respond to the complaint;
4. The requested extension is needed for the following reasons: (1) defendants' counsel has an upcoming pre-planned annual meeting with his law firm, the costs for which have already been paid; (2) due to defendants' counsel's recent retention and need to get up to speed on the case; and (3) to provide sufficient time to explore a potential early resolution to the case.
5. Accordingly, the parties stipulate and agree to extend the time for defendants to respond to the complaint to November 26, 2018.
6. The parties also stipulate and agree that, in the event defendants file a motion under FRCP 12, Viaggio's time to respond to the motion shall be extended by at least an additional two weeks beyond the standard opposition period under the local rules, due to deposition and case commitments Viaggio's counsel has during the end of November and first part of December of 2018.
7. This stipulation is not entered for any improper purpose or to delay.
IT IS SO STIPULATED.
Defendants' new deadline to respond to the complaint shall be November 26, 2018.