JOINT STIPULATION AND [PROPOSED] ORDER TO: (1) MODIFY BRIEFING SCHEDULE ON PLAINTIFFS' MOTION FOR CLASS CERTIFICATION; (2) SET DATES FOR CASE MANAGEMENT CONFERENCE AND MOTION FOR CLASS CERTIFICATION

*AS MODIFIED BY THE COURT*

YVONNE GONZALEZ ROGERS, District Judge.

Defendants ("Dollar") and Plaintiffs (collectively, the "Parties") file this joint stipulation pursuant to Fed. R. Civ. P. 16(b)(4); and Civil L.R. 7-12, 6-1(b), and 6-2 to request that the Court: (1) continue the date of the Case Management Conference and hearing on the pending motion for class certification so that both matters are heard on the same date, as set forth below, and (2) modify the deadline for filing the reply brief related to Plaintiffs' Amended Motion for Class Certification as set forth below.

1. Case Management Conference Date. On December 4, 2015, the Court entered a Case Management Scheduling Order, providing for a Case Management Conference on February 22_, 2016 at 2 p.m. (ECF No. 151.) The Parties jointly request, for the reasons set forth in the attached declaration of Alan M. Mansfield, that the Court amend the Case Management Scheduling Order to set the Case Management Conference as the same date as the hearing on the pending motion for class certification.

2. Briefing and Hearing Schedule on Class Certification Motion. On November 18, 2015, the Court granted the Parties' motion to amend the briefing and hearing schedule for Plaintiffs' Amended Motion for Class Certification ("Amended Motion"). (ECF No. 147.) Under the current briefing schedule, Plaintiffs' Reply papers in support of the Amended Motion are due by January 12, 2016, and the hearing on the motion is set for February 9, 2016. As set forth in the Declaration of Alan M. Mansfield, in connection with their Opposition Dollar submitted the Declarations of several individuals, including three Dollar employees in Southern California. Based on negotiations between counsel for the parties, depositions of those Declarants have just recently been set for January 14, 2016. As a result, the parties are in agreement to move the deadline for Plaintiffs to file the reply brief for two weeks, until January 26, 2016, and continue the hearing date on the motion for class certification to February 22, 2016, the present date as the Case Management Conference.

If the Court prefers to hold a hearing on this motion on February 23, 2016 on its regular motion calendar date, the parties would request the Case Management Conference be continued to take place on that date.

ORDER

PURSUANT TO THE PARTIES' STIPULATION, IT IS ORDERED that:

1. Plaintiffs' Reply In Support of the Amended Motion for Class Certification is due on January 26, 2016.

2. The hearing on Plaintiffs' class certification motion is CONTINUED to February 23, 2016 at 2 p.m.

3. The Case Management Conference is also CONTINUED and shall be held at the same date and time as the hearing on Plaintiffs' class certification motion.

This Order terminates Docket Number 157.