JOINT STIPULATION AND REQUEST TO CONTINUE THE DEADLINE FOR WALMART'S RESPONSIVE PLEADINGS AND THE PARTIES' JOINT STATUS REPORT

JOHN A. MENDEZ, District Judge.

On August 16, 2019, Plaintiff filed her First Amended Complaint against Defendant Walmart, Inc. The First Amended Complaint added a new defendant, Wal-Mart Associates, Inc. On August 23, 2019, Walmart Associates, Inc. agreed to accept service of the complaint.

As a result, the two Walmart defendants have two different responsive pleading deadlines: the deadline for Walmart, Inc. to respond to the First Amended Complaint is August 30, 2019, while Wal-Mart Associate's responsive pleading is not due until September 13, 2019.

To avoid confusion, and the need for two separate filings, the parties jointly propose that both Walmart defendants have until September 13, 2019 to respond to the First Amended Complaint.

In addition, the deadline for the parties to submit their revised joint status report, with a proposed scheduling order and discovery plain, is currently set for September 6, 2019. However, in accordance with this Court's May 13, 2019 Order, the parties intend to meet and confer regarding Walmart's anticipated motion to dismiss to avoid the need for unnecessary motion practice.

Thus, to account for any scheduling matters arising out of the parties' meet and confer and potential motion to dismiss, the parties propose that the deadline to submit a revised joint status report, with a proposed scheduling order and discovery plan, be extended to September 20, 2019, one week after the deadline for Defendants to respond to Plaintiff First Amended Complaint.

Thus, the parties request that the Court enter the following scheduling order:

PURSUANT TO STIPULATION, IT IS SO ORDERED

SIGNATURE ATTESTATION

Aaron Winn, the ECF User whose ID and Password are being used to file this Joint Stipulation and Request, attest that Michael Stahle, the other signatory counsel, has concurred with the filing of this document.