RICHARD SEEBORG, District Judge.
In accordance with Local Rule 6-2(a), Plaintiff Anthony Gilbert Santos ("Plaintiff") and Defendants CarMax, Inc., CarMax Auto Superstores California, LLC, CarMax Business Services, LLC, and CarMax Auto Superstores West Coast, Inc. (collectively, "Defendants"), by and through their respective counsel, respectfully submit this Stipulation and Proposed Order to Extend Case Deadlines:
WHEREAS, the Court entered a Case Management Scheduling Order on May 17, 2018 providing that a hearing on Plaintiff's forthcoming Motion for Class Certification would be held on February 14, 2019 at 1:30 p.m. (Dkt. No. 58);
WHEREAS, Christopher Noyes began serving as co-counsel for Plaintiff and noticed his appearance in this matter on December 3, 2018 (Dkt. No. 62); and
WHEREAS, the Parties need additional time to continue their discussions regarding an informal resolution to this matter.
THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff and Defendants that an extension of the class certification hearing deadline is necessary to permit Plaintiff's new co-counsel to review the issues present in this case and appropriately prepare briefing for a hearing on Plaintiff's forthcoming Motion for Class Certification. Therefore, the parties jointly request an extension of the Court's Case Management Scheduling Order, (Dkt. No. 58), for a period not to exceed
The parties jointly acknowledge that all class certification briefing must be completed no later than two weeks prior to the Court's hearing date. Therefore, the parties stipulate to the following class certification briefing schedule:
The Court previously extended the date of the Initial Case Management conference on July 12, 2017 and January 19, 2018 respectively. (Dkt. Nos. 10 and 44.) On January 30, 2018, the parties obtained an extension of the briefing deadlines relating to Defendants' response to Plaintiff's Second Amended Complaint. (Dkt. No. 46.) The deadline for the hearing on class certification has not previously been extended in this matter.
The parties jointly request an order to extend the date of the hearing on Plaintiff's Motion for Class Certification to
Pursuant to L.R. 5-1(i)(3), the undersigned hereby attests that all parties have concurred in the filing of this stipulation.
Chad R. Fuller