STIPULATION AND ORDER TO EXTEND BRIEFING DEADLINES AND CONTINUE HEARING ON MOTION FOR JUDGMENT ON THE PLEADINGS AND FURTHER CASE MANAGEMENT CONFERENCE;

DECLARATION OF KERRY C. FOWLER IN SUPPORT THEREOF

Civil L.R. 6-2

WILLIAM H. ORRICK, District Judge.

STIPULATION

Pursuant to Civil Local Rule 6-2, Plaintiff Sean DeVries ("Plaintiff") and Defendant Experian Information Solutions, Inc. ("Defendant," and Plaintiff and Defendant, collectively, are the "Parties"), by and through their undersigned counsel, stipulate as follows, subject to a Court Order approving the stipulation:

WHEREAS, on January 23, 2018, the Court entered a Minute Entry (Doc. No. 72) granting Defendant one week to file a Motion for Judgment on the Pleadings and setting February 28, 2018 as the date for a hearing on such motion;

WHEREAS, the Court also set a Further Case Management Conference for February 28, 2018, to be heard at the same time as the Motion for Judgment on the Pleadings;

WHEREAS, on January 24, 2018, Defendant filed the its Motion for Judgment on the Pleadings ("Motion") (Doc. No. 73);

WHEREAS, Civil Local Rule 7-3(a) sets February 7, 2018 as the deadline for Plaintiff to file an Opposition to the Motion;

WHEREAS, Civil Local Rule 7-3(c) sets February 14, 2018 as the deadline for Defendant to file a Reply in Support of the Motion;

WHEREAS, due to certain conflicts, the Parties require additional time for briefing and wish to stipulate to an extension of the briefing schedule for the Motion as follows:

WHEREAS, the Parties also wish to reschedule the hearing on the Motion and Further Case Management Conference to March 14, 2018 at 2:00 p.m.;

WHEREAS, the Parties agree that this Stipulation shall have no force or effect unless the Court approves the Stipulation in its entirety and enters the [Proposed] Order set forth below;

NOW, THEREFORE, pursuant to Civil Local Rule 6-2, the Parties hereby stipulate and request that the Court enter an Order amending the briefing and hearing schedules as follows:

The Hearing on the Motion is rescheduled for March 14, 2018 at 2:00 p.m.; and

The Further Case Management Conference previously scheduled for February 7, 2018 is continued to March 14, 2018 at 2:00 p.m.

DECLARATION OF KERRY C. FOWLER

I, Kerry C. Fowler, declare as follows:

1. I am a member in good standing of the State Bar of California, and am admitted to practice before the Northern District of California and other federal courts. I am a partner in the law firm of Jones Day, attorneys of record for defendant Experian Information Solutions, Inc. ("EIS") in the above-captioned action.

2. On January 23, 2018, the Court entered a Minute Entry (Doc. No. 72) granting EIS one week to file a Motion for Judgment on the Pleadings, and setting February 28, 2018 as the date for a hearing on such motion. The Court also set a Further Case Management Conference for February 28, 2018, to be heard at the same time;

3. On January 24, 2018, EIS filed its Motion for Judgment on the Pleadings (the "Motion"). Subsequent to the filing of the Motion, counsel for the parties engaged in a series of meet and confer communications regarding certain conflicts that had arisen with the February 28, 2018 hearing date.

4. On February 7, 2018, counsel reached an agreement regarding a mutually acceptable briefing schedule and the available hearing date of March 14, 2018.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed this 7th day of February, 2018 in Los Angeles, California.

ATTESTATION

Pursuant to Civil Local Rule 5-1(i)(3), I, Kerry C. Fowler attest under penalty of perjury under the laws of the United States that concurrence in the filing of this document has been obtained from all of the signatories.

[PROPOSED] ORDER

Based upon the Stipulation of the Parties, and for good cause shown, the Court hereby amends the briefing and hearing schedules on Defendant Experian Information Solutions, Inc.'s Motion For Judgment on the Pleadings and the Further Case Management Conference as follows:

The Hearing on the Motion is rescheduled for March 14, 2018 at 2:00 p.m.; and

The Further Case Management Conference previously scheduled for February 7, 2018 is continued to March 14, 2018 at 2:00 p.m.

IT IS SO ORDERED.