STIPULATION AND [PROPOSED] ORDER REGARDING SECOND AMENDED COMPLAINT

VINCE CHHABRIA, District Judge.

TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD:

Plaintiff Terria Harris and Defendant Home Depot U.S.A., Inc. ("Home Depot") (collectively, the "Parties") hereby submit this Stipulation and Proposed Order, as follows:

WHEREAS, as discussed in the Parties' Joint Case Management Conference Statement, Plaintiff Harris intends to seek leave to file an amended complaint;

WHEREAS, Home Depot has agreed to stipulate to the filing of an amended complaint, subject to Home Depot's express reservation of all defenses and responses thereto;

WHEREAS, Plaintiff anticipates being prepared to file the amended complaint within 30 days;

WHEREAS, Plaintiff agrees that in light of this stipulation, Home Depot need not answer the operative First Amended Complaint;

NOW, THEREFORE, the Parties hereby STIPULATE AND AGREE as follows, subject to the Court's approval:

1. Plaintiff's Second Amended Complaint shall be filed no later than August 14, 2015;

2. Home Depot shall not be required to answer the First Amended Complaint;

3. Home Depot's response to the Second Amended Complaint shall be due on September 11, 2015; and

4. No other scheduling dates shall be affected by this stipulation.

[PROPOSED] ORDER

The Court has read and considered the Parties' Stipulation Regarding Second Amended Complaint. GOOD CAUSE APPEARING, the Court hereby ORDERS as follows:

1. Plaintiff's Second Amended Complaint shall be filed no later than August 14, 2015;

2. Home Depot shall not be required to answer the First Amended Complaint;

3. Home Depot's response to the Second Amended Complaint shall be due on September 11, 2015; and

4. No other scheduling dates shall be affected by this Order.

IT IS SO ORDERED.