THE PARTIES' STIPULATION and (PROPOSED) ORDER TO RESET THE COURT'S HEARING ON DEFENDANT'S MOTION, NOW SET FOR JUNE 13, 2019

(First Request)

CAM FERENBACH, Magistrate Judge.

Plaintiff and Counter-defendant, NEVADA TITLE COMPANY, ("NTC") by its counsel, Steven J. Parsons, of LAW OFFICES OF STEVEN J. PARSONS, and Defendant and Counter-claimant, ACE AMERICAN INSURANCE COMPANY, ("ACE American") by its counsel, Michael W. Melendez, of COZEN O'CONNOR, hereby stipulate to seek the Court's resetting of Defendant's Motion to Modify Scheduling Order to Phase Discovery and Schedule Dispositive Motions on Claims Relating to NTC's Prior Knowledge (ECF No. 37) from Thursday, June 13, 2019 (set by this Court's Order on June 5, 2019, ECF No. 49) to a later date, for the reasons outlined herein.

This Stipulation between the parties to reset this Hearing is the first request; Plaintiff's counsel had planned to accompany his spouse in driving to southern California on the morning of Thursday, June 13, 2019 for professional work and other appointments on Friday, June 14, 2019 — including with Counsel's longtime Ophthalmologist to review recent changes in Counsel's vision; and, to attend the graduation of their son from the University of California — Riverside and to celebrate Father's Day in California on the same day, Sunday, June 16, 2019. This request by Plaintiff's counsel, and the gracious concession by Defendant's counsel to not oppose this Request, is upon good cause and is not simply for the purposes of delay.

The parties' counsel have met and conferred and are available to attend a reset hearing on:

ORDER

IT IS SO ORDERED.

Upon the foregoing Stipulation of the parties, the Hearing on Defendant's Motion, presently set for Thursday, June 13, 2019 shall now be at 2:30 PM, o'clock, on 6-21-2019, in Ctrm 3D.