STIPULATION AND ORDER FOR CONTINUANCE OF INITIAL SCHEDULING CONFERENCE
Comes now, the parties hereto, by and through their respective counsel, and hereby stipulate and request that the court continue the Initial Scheduling Conference presently set for October 18, 2010 until sometime after November 8, 2010, but prior to November 29, 2010*fn1 , at a date and time convenient to the court for the following reasons:
1. By court order, the Initial Scheduling Conference was set for September 13, 2010. See, Order attached hereto as Exhibit A.
2. On August 26, 2010, the court entered a Minute Order on its own continuing the Initial Scheduling Conference to October 18, 2010. See, Minute Order attached hereto as Exhibit B.
3. At the time the August 26, 2010 Minute Order was issued, William E. Cooper, lead counsel for Defendants Bally Technologies and Aetna was scheduled to be out of the country on a business trip to Namibia, Africa, from October 13, 2010 through November 3, 2010. See, Declaration of William E. Cooper, Esq., attached hereto as Exhibit C.
Based upon the foregoing, this stipulation and request for continuance is made in good faith and not for the purpose of delay. Because lead counsel for Defendants Bally Technologies and Aetna had a prior commitment to be out of the country on October 18, 2010, before the court changed the Initial Scheduling Conference from September 13, 2010 to October 18, 2010, the parties through their respective counsel hereby stipulate and request that the October 18, 2010 hearing date be continued until sometime after November 8, 2010, but prior to November 29, 2010, at a time and date convenient to the court.
This is the first request to continue the Initial Scheduling Conference.
The Initial Scheduling Conference will be continued to November 15, 2010, at 3:00 p.m. Status reports from the respective parties will be due fourteen (14) days prior to the status conference.
IT IS SO ORDERED this 27th day of ...