STIPULATION AND ORDER TO EXTEND TIME TO FILE DISPOSITIVE MOTIONS (FIRST REQUEST)

PEGGY A. LEEN, Magistrate Judge.

Pursuant to LR IA 6-1, the parties, by and through their undersigned counsel of record, hereby agree and jointly stipulate that the dispositive motion deadline in this case, currently set for November 26, 2018, be extended an additional sixty-three (63) days up to and including Monday, January 28, 2019. The following grounds constitute good cause for granting this extension:

1. The parties conducted discovery including depositions up and until the October 29, 2018 discovery cut-off.

2. Many of the deposition transcripts have not been received and are necessary for the dispositive motion briefing. The parties understand that some transcripts will not be complete until early/mid December.

3. All counsel have scheduling conflicts with the upcoming holidays that would require various extensions with respect to the filing of responses and replies.

4. Plaintiffs' counsel has a scheduled honeymoon beginning on December 26, 2018 through January 12, 2019.

5. Rather than file dispositive motions and then extend the time for all subsequent responsive pleadings, the parties believe that it is best to extend the dispositive motion out until the end of January.

6. All parties agree that discovery is closed and all parties agree that no further discovery will be conducted or attempted.

This stipulation for an extension of time is also not sought for any improper purpose or other purpose of delay, but in the interest of each party effectively representing their clients at the dispositive motion stage.

ORDER

IT IS HEREBY ORDERED that the dispositive motion deadline in this case, currently set for November 26, 2018, be extended an additional sixty-three (63) days up to and including Monday, January 28, 2019.

IT IS SO ORDERED.