JOINT STIPULATION OF PARTICULARIZED GOOD CAUSE AND ORDER EXTENDING DISCOVERY SCHEDULE AND OTHER DEADLINES

Civil L.R. 6-2.

HAYWOOD S. GILLIAM, JR., District Judge.

Plaintiffs Nancy Coe, Tori Castro, and Pamela Mizzi (collectively, "Plaintiffs") and Defendant General Mills, Inc. ("Defendant") (collectively with Plaintiffs, the "Parties"), by and through their undersigned counsel, stipulate as follows, subject to an Order approving the Stipulation:

WHEREAS, on November 16, 2017, the Court held a telephone conference and, thereafter, entered the following deadlines [ECF No. 78]:

WHEREAS the Parties had agreed to engage in a 2-day mediation on February 21 and 22, 2018, in Los Angeles, California, with the Hon. Peter D. Lichtman (Ret.) of JAMS. The Parties mediated with Judge Lichtman on February 21, 2018 and the case did not settle. By agreement, the Parties postponed the second day of mediation;

WHEREAS Judge Lichtman remained engaged with the Parties via telephone and email for an extended period, and on March 12, 2018 made a mediator's proposal for certain components of a settlement. On March 19, 2018, Judge Lichtman informed the parties that both sides had accepted the mediator's proposal for portions of a settlement, and requested a further mediation to seek to complete open issues remaining with respect to a potential settlement. In accordance with Judge Lichtman's request, the Parties have rescheduled the second day of mediation for May 14, 2018, in Los Angeles, California, which is Judge Lichtman's next available date;

WHEREAS, in order to preserve the resources of both the Court and the Parties, the Parties have agreed that completion of the remaining class certification discovery should be stayed pending the continued mediation without prejudice to resume discovery should this case not resolve through mediation;

WHEREAS the Parties recognize that the Court requires particularized good cause for revising the schedule and the Parties agree that: (1) they have sufficient information and discovery for a potentially successful mediation; (2) the Parties entered the mediation in good faith in an effort to resolve this matter; (3) the Parties agree that Judge Lichtman is a particularly effective mediator and has assisted the Parties in making substantial progress towards a resolution; (4) Judge Lichtman's, the Parties' and counsel's schedules will only allow for the second day mediation in May on the date specified; (5) the mediation and the potential for a resolution will avoid the expenditure of significant resources of the Parties in conducting discovery and significant resources of the Court in resolving potential discovery disputes; and (6) given certain discovery issues, the potential for resolution with discovery continued as specified constitutes enhances the likelihood for a successful mediation. The Parties believe the foregoing constitutes good cause for this modification of the schedule;

WHEREAS the Parties have agreed that the cutoff for Class Certification Discovery shall be 40 days after the conclusion of the mediation if not successful, which cutoff date shall be subject to hearings and rulings on motions to compel which may necessitate an extended discovery cutoff date;

WHEREAS, based on the stay of discovery pending mediation, the Parties likewise agree that the remaining dates related to Class Certification briefing and expert disclosure and discovery in the current case schedule should be adjusted correspondingly, pursuant to the Court's permission and would submit a proposed schedule following the mediation if the mediation is not successful;

WHEREAS, the Parties seek no other modification to the schedule; specifically, there is no request to move a Date Set for Dispositive Motions, a Pre-Trial Conference Date, or a Trial Date;

NOW, THEREFORE, the Parties hereby stipulate and request that the Court enter an order staying all further discovery and all Class Certification related deadlines.

ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3)

I, Laurence D. King, attest that concurrence in the filing of this document has been obtained from the other signatory. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed this 9th day of April, 2018, in San Francisco, California.

ORDER

Pursuant to the foregoing Stipulation, the revised discovery schedule and briefing scheduled as stated above is SO ORDERED.