STIPULATION AND PROPOSED ORDER ALLOWING PLAINTIFF TO AMEND COMPLAINT AND EXTENDING DEADLINE FOR DEFENDANTS' RESPONSE THERETO

EDWARD M. CHEN, District Judge.

Pursuant to Local Rule 7-12, it is stipulated between Plaintiff Susan Harvey and Defendant Google Inc. by their respective attorneys:

1. WHEREAS, on April 15, 2015, Plaintiff filed in her Complaint in the Eastern District of California, see Dkt. No. 1;

2. WHEREAS, on June 25, 2015, Defendant filed a Motion to Transfer or Dismiss, seeking to transfer this matter to the Northern District of California or, alternatively, dismiss the action, see Dkt. No. 10;

3. WHEREAS, on August 4, 2015, pursuant to a stipulation by the parties, the Eastern District of California entered an order transferring this action to this Court, see Dkt. No. 20;

4. WHEREAS, pursuant to Federal Rule of Civil Procedure 15(a)(2), Defendant has agreed to allow Plaintiff to amend her Complaint;

5. WHEREAS, pursuant to Local Rule 6-1(b), the parties have agreed to extend the time within which Defendant must answer or respond to Plaintiff's amended complaint;

6. WHEREAS, the parties do not believe that this extension will alter any currently existing deadlines or the current case schedule;

7. By entering into this Stipulation, Defendant does not waive any defenses, rights, or privileges.

THEREFORE, the Parties hereby stipulate and agree to the following:

1. Plaintiff may file an amended complaint on or before September 30, 2015.

2. Because this case has been transferred to this Court and because Plaintiff will file an amended complaint, Defendant withdraws its Motion to Transfer or Dismiss, Dkt. No. 20;

3. Defendant's deadline to respond to the Complaint, whether by answer, motion, or otherwise, shall be extended to October 30, 2015.

Local Rule 5-1(i) Attestation

I, Susan D. Fahringer, hereby attest, pursuant to N.D. Cal. Local Rule5-1(i), that the concurrence to the filing of this document has been obtained from each signatory hereto.

[PROPOSED] ORDER

PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED. Plaintiff shall file an amended complaint on or before September 30, 2015. Defendant's deadline to respond to the Complaint, whether by answer, motion, or otherwise, shall be extended to October 30, 2015.

IT IS SO ORDERED.