STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING TO PLAINTIFF'S COMPLAINT
NANCY J. KOPPE, Magistrate Judge.
Defendant, AMERICAN HONDA FINANCE CORPORATION (hereinafter "AHFC"), by and through its counsel of record, CHAD C. BUTTERFIELD, ESQ., of the law firm WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP, and Plaintiff, GREGORY P. ROMBOLETTI, by and through his counsel of record, DAVID H. KRIEGER, ESQ. of the law firm HAINES & KRIEGER, LLC hereby stipulate and agree to extend the deadline for filing a responsive pleading to June 21, 2017.
This stipulation is submitted in compliance with LR IA 6-1. Good cause exists for the requested extension, as counsel for AHFC has only recently been retained to represent AHFC in this matter and has only recently obtained the relevant file materials and information necessary to respond to the allegations set forth in the Complaint. Accordingly, the parties agree that the requested extension furthers the interests of this litigation and is not being requested in bad faith or to delay these proceedings unnecessarily.
This is the parties' first request for extension of the deadline. The parties' failure to file this stipulation on or before June 7, 2017 (i.e., the original responsive pleading deadline) was the result of a clerical error by counsel for AHFC's former legal assistant, who inadvertently failed to calendar the deadline. Counsel for AHFC immediately contacted Plaintiff's counsel to request a stipulation to extend the deadline upon realizing that the responsive pleading deadline had passed. Plaintiff's counsel graciously agreed to the requested extension. Accordingly, the parties respectfully submit that the failure to submit this stipulation on or before June 7, 2017 was the result of excusable neglect.