STIPULATION TO AMEND SCHEDULING ORDER

JON S. TIGAR, District Judge.

Plaintiffs Amber Hawthorne, Christopher Kneer, and Victoria Kneer (collectively, "Plaintiffs") and Defendant Umpqua Bank ("Defendant"), by and through their respective attorneys of record, stipulate and agree as follows:

WHEREAS, pursuant to the Court's Scheduling Order (Docket No. 54), deadlines have been set for class certification motion briefing in advance of a June 5, 2014 class certification hearing. Plaintiffs' motion for class certification is currently due to be filed on March 20, 2014, and Defendant's opposition to that motion is currently due to be filed on April 25, 2014.

WHEREAS, the Parties have been working together to complete the discovery that Plaintiffs seek in advance of the proceedings on class certification. Defendant concluded its document production in October 2013. However, in light of the Court's recent order granting Plaintiffs leave to file their Third Amended Complaint, Defendant has agreed to supplement its document production and a number of its prior interrogatory responses. Defendant is currently in the process of gathering and preparing documents for the supplemental production it agreed to provide, and has determined that a large portion of those documents are maintained in hard copy format only, making it more time consuming to gather, scan, upload, and process those documents so they may be produced in the format Plaintiffs requested. Defendant anticipates the production of a few thousand pages of documents.

WHEREAS, the Parties are currently in the process of finalizing dates to complete the depositions of Defendant's representatives, which were delayed while the parties met and conferred to resolve their dispute regarding the scope of the original Federal Rule of Civil Procedure 30(b)(6) deposition notice that Plaintiffs served on Defendant. One Rule 30(b)(6) deposition was convened on December 20, 2013 on limited topics. Plaintiffs would like the opportunity to review the supplemental production that Defendant has agreed to provide in advance of taking any further depositions.

WHEREAS, the Parties agree that a short extension of time for Plaintiffs to file their motion for class certification is reasonable under the above-described circumstances, and that commensurate extensions should be made to the other class certification briefing deadlines.

WHEREAS, the Scheduling Order does not provide a deadline for Plaintiffs to file their reply brief in support of class certification, and the Parties would like to set a clear deadline for Plaintiffs to file a reply brief to remove any potential ambiguity.

IT IS HEREBY STIPULATED THAT:

Currently, June 5, 2014 at 2:00 p.m. is the hearing date on Plaintiffs' class certification motion and further Case Management Conference. The Parties are conscious the Court will want sufficient time to review and analyze the Parties' class certification briefing and evidence, and that the requested amendments to the briefing schedule may impact the Court's preparation for the hearing. As such, the Parties respectfully request that the Court advise them of a new date and time for the hearing and further Case Management Conference. Above, the Parties agree to file a Joint Case Management Statement no later than 14 days prior to the Case Management Conference, which time period is consistent with the existing Scheduling Order.

Pursuant to Local Civil Rule 6-2(a), attached as Exhibit A is a joint declaration in support of this Stipulation.

PURSUANT TO STIPULATION, IT IS SO ORDERED.