6-1(b) and 6-2, Plaintiff Sonni Echeverria-Corzan (“Plaintiff”) and Defendant Dolls Kill, Inc. (“Defendant,” and together with Plaintiff, the “Parties”), by and through their respective undersigned counsel of record, hereby stipulate as follows: WHEREAS, on September 25, 2024, the Parties filed a stipulation requesting to continue the Initial Case Management Conference from October 8, 2024, at 2:00 p.m., to December 17, 2024, and to adjust associated deadlines (Dkt. 17), and the Court issued an Order granting the Parties stipulation (Dkt. 18); WHEREAS, on November 19, 2024, the Parties participated in an in-person, full-day mediation of this matter before the Honorable Judge Louis Meisinger; WHEREAS, the Parties have reached a settlement and are currently in the process of finalizing a long-form settlement agreement; WHEREAS, on December 16, 2024, the Parties filed a stipulation requesting to continue the Initial Case Management Conference from December 17, 2024, at 2:00 p.m., to February 11, 2025, and to adjust associated deadlines (Dkt. 19); WHEREAS, the Court issued an Order granting the Parties’ stipulation and stayed the case for all purposes through the rescheduled Initial Case Management Conference to take place on February 11, 2025 (Dkt. 20); WHEREAS, on February 6, 2025, the Parties filed a stipulation requesting to continue the Initial Case Management Conference from February 11, 2025, at 2:00 p.m., to March 11, 2025, and to adjust associated deadlines (Dkt. 21); WHEREAS, the Court issued an Order granting the Parties’ stipulation and stayed the case for all purposes through the rescheduled Initial Case Management Conference to take place on March 11, 2025 (Dkt. 22); WHEREAS, on March 5, 2025, the Parties filed a stipulation requesting to continue the Initial Case Management Conference from March 11, 2025, at 2:00 p.m., to April 15, 2025, and to adjust associated deadlines (Dkt. 23); Joint Stipulation to Stay Case and Continue Initial Case Management Conference Case No. 3:24-cv-02040-WHO WHEREAS, the Court issued an Order granting the Parties’ stipulation and stayed the case for all purposes through the rescheduled Initial Case Management Conference to take place on April 15, 2025 (Dkt. 24); WHEREAS, the Parties are still in the process of finalizing a long-form settlement agreement and require more time to complete it; WHEREAS, in order to conserve resources while finalizing the settlement documentation, the Parties stipulate, agree, and respectfully request that the Court extend the stay through May 13, 2025, reset the Initial Case Management Conference for May 13, 2025, at 2:00 p.m., or a later date otherwise convenient for the Court, and that if the case is not dismissed before that conference, set a deadline for Defendant to respond to the Complaint at the conference; WHEREAS, this is the Parties’ sixth request to continue the Initial Case Management Conference, is for good cause, and no party would be prejudiced by the proposed continuance and extension; THEREFORE, IT IS STIPULATED and agreed, subject to the Court’s approval, as follows:
The case is stayed for all purposes through and including May 13, 2025, at 2:00 p.m., at which time the Court will hold an Initial Case Management Conference and set deadlines in this case, including Defendant’s deadline to respond to the Complaint , or to such later date that is convenient for the Court;
The only exception to this stay is that seven days before the Initial Case Management Conference, the Parties shall provide the Court with the status of settlement.
In compliance with Civil Local Rule 5-1(i)(3), I attest that all other counsel on whose behalf this filing is jointly submitted have approved of and concurred in this filing.
The initial Case Management Conference is set for June 3, 2025 at 2:00 p.m.