STIPULATION SETTING DEFENDANTS' RESPONSE DATE TO THE COMPLAINT

WILLIAM H. ALSUP, District Judge.

Plaintiff Kathryn Workman ("Plaintiff") and defendants Plum, PBC d/b/a Plum Organics (erroneously sued as Plum Inc.) and Campbell Soup Company ("Defendants") (collectively, the "Parties"), by and through their respective counsel of record and pursuant to Local Rule 6-2, enter into the following stipulation extending the time in which Defendants must respond to the complaint and setting a schedule on a motion to dismiss:

WHEREAS, on June 9, 2015, plaintiff filed the Complaint in the above-captioned action;

WHEREAS, on June 11, 2015, the Complaint was served on defendants (Dkt. Nos. 12, 13);

WHEREAS, based on the June 11, 2015 service, defendants' response to the Complaint was due on July 2, 2015;

WHEREAS, shortly after service of the Complaint, and based on the unique record presented, the Parties began discussions about the potential for an early resolution of this action;

WHEREAS, on July 1, 2015, prior to the expiration of defendants' time to respond to the Complaint, the Parties submitted a stipulation for a limited ninety (90) day stay of this action (Dkt. No 14) to commence discussions regarding an early resolution of this action;

WHEREAS, on July 23, 2015, and following assignment of the case to the Honorable William H. Alsup, the Parties re-submitted their stipulation for a limited ninety (90) day stay of this action to this Court (Dkt. No. 21);

WHEREAS, on July 24, 2015, the Court denied the stipulation for a limited ninety (90) days stay of this action (Dkt. No. 22);

WHEREAS, the Parties now wish to set August 27, 2015, twenty-one (21) days from the date of the filing of this stipulation, as the deadline for defendants to respond to the Complaint;

WHEREAS, the parties would like to use this opportunity also to set forth a briefing schedule for Defendants' anticipated motion to dismiss that allows the parties sufficient time;

WHEREAS, the Parties have not previously sought an extension to the time to respond to the Complaint.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the Parties through their respective counsel, subject to the approval form the court, that:

1. Defendants shall respond to the complaint by August 27, 2015.

2. Plaintiff shall file their opposition to Defendants' motion to dismiss by September 25, 2015.

3. Defendants' reply shall be filed by October 8, 2015.

4. The motion shall be noticed for an October 29, 2015 hearing date, or on such other date and time that is convenient for the Court and its calendar.

[PROPOSED] ORDER

Pursuant to stipulation, it is SO ORDERED that:

1. Defendants shall respond to the complaint by August 27, 2015.

2. Plaintiff shall file their opposition to Defendants' motion to dismiss by September 25, 2015.

3. Defendants' reply shall be filed by October 8, 2015.

4. The motion shall be noticed for an October 29, 2015 hearing date, or on such other date and time that is convenient for the Court and its calendar.