JOINT STIPULATION FOR ENLARGEMENT OF TIME TO RESPOND TO COMPLAINT AND TO RESCHEDULE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER [CIVIL L.R. 6-1(b)]

SAUNDRA BROWN ARMSTRONG, District Judge.

Pursuant to Civil L.R. 6-1(b), Defendants Von Curtis, Inc., P.M. Advanced Education Inc., Paul Mitchell Advanced Education LLC, PMNV Las Vegas, LLC, PMCA Bakersfield, LLC, PMHBW LLC, Winn Claybaugh, John Paul DeJoria, Paul Mantea, D'Ann Evans, and Ann-Marie Safadi ("Defendants"), and Plaintiffs Jessica Morales, Berenisa Cortes Palominos, Dylan Thomas, Janette Barrera, and Frances Handcock ("Plaintiffs"), by and through their undersigned counsel in the above-captioned matter, hereby stipulate as follows:

WHEREAS, Plaintiffs filed a Complaint against Defendants on or about October 25, 2013;

WHEREAS, on January 7, 2014, Plaintiffs requested that the Court reschedule the initial Case Management hearing then scheduled for January 30, 2014, because service of process had not yet been performed on any of the Defendants (Doc. No. 7);

WHEREAS, on January 9, 2014, the Court issued an "Order Rescheduling Hearing to March 6, 2014 and Directing Service of Process," which reset the initial Case Management Conference date to March 6, 2014, at 11:00 a.m., and stated the "case management conference may be continued by stipulation thereafter." (Doc. No. 8);

WHEREAS, Plaintiffs served Defendant PMNV Las Vegas and purportedly served Defendant Ann-Marie Safadi on or about January 28, 2014, Defendant Paul Mitchell Advanced Education, LLC on or about January 29, 2014, and Defendants Winn Claybaugh and Von Curtis, Inc. on or about February 5, 2014;

WHEREAS, Defendants PMNV Las Vegas, and Ann-Marie Safadi, Paul Mitchell Advanced Education, LLC, Winn Claybaugh, and Von Curtis, Inc. agree to waive any objections to service, and counsel for Defendants P.M. Advanced Education Inc., PMCA Bakersfield, LLC, PMHBW LLC, John Paul DeJoria, Paul Mantea, and D'Ann Evans, agree to acknowledge service on behalf of Defendants PMCA Bakersfield, LLC, PMHBW LLC, John Paul DeJoria, Paul Mantea, and D'Ann Evans and to waive any objection to service, and in return, Plaintiffs agree to extend the time for Defendants Von Curtis, Inc., P.M. Advanced Education Inc., Paul Mitchell Advanced Education, LLC, PMNV Las Vegas, PMCA Bakersfield, LLC, PMHBW LLC, Winn Claybaugh, John Paul DeJoria, Paul Mantea, D'Ann Evans, and Ann-Marie Safadi to respond to the Complaint to and including April 8, 2014;

WHEREAS, Defendants do not waive any defenses or objections, other than service of the Complaint, by entering into this Stipulation;

WHEREAS, this Stipulation for Enlargement of Time for Defendants to file a responsive pleading affects the March 6, 2014 initial Case Management Conference date on the Court's calendar and other related deadlines. As such, the parties agree that the Case Management Conference should be rescheduled to May 8, 2014, at 11:00 a.m., subject to the Court's availability.

IT IS HEREBY STIPULATED by and between Plaintiffs, on the one hand, and Defendants, on the other, through their respective counsel of record, that Defendants Von Curtis, Inc., P.M. Advanced Education Inc., Paul Mitchell Advanced Education, LLC, PMNV Las Vegas, PMCA Bakersfield, LLC, PMHBW LLC, Winn Claybaugh, John Paul DeJoria, Paul Mantea, D'Ann Evans, and Ann-Marie Safadi have an extension of time to file a responsive pleading to the Complaint to and including April 8, 2014;

IT IS ALSO HEREBY STIPULATED that, subject to the Court's availability, the initial Case Management Conference in this matter currently set for March 6, 2014, at 11:00 a.m. be continued to a proposed date of May 8, 2014, at 11:00 a.m., and that the other deadlines set forth in the Court's Order Setting Initial Case Management Conference and Deadlines issued on October 25, 2013 (Doc. No. 4) be continued accordingly.

IT IS SO STIPULATED.

ATTESTATION: Pursuant to Civil L.R. 5-1(i)(3), the filer attests that concurrence in the filing of this document has been obtained from each of the other signatories thereto.

ORDER

The Court having considered the Joint Stipulation for Enlargement for Time to Respond to Complaint and To Reschedule Case Management Conference, orders as follow: the initial Case Management Conference set for March 6, 2014, at 11:00 a.m. shall be continued to May 8, 2014, at 11:00 a.m. Defendants Von Curtis, Inc., P.M. Advanced Education Inc., Paul Mitchell Advanced Education, LLC, PMNV Las Vegas, PMCA Bakersfield, LLC, PMHBW LLC, Winn Claybaugh, John Paul DeJoria, Paul Mantea, D'Ann Evans, and Ann-Marie Safadi have up to and including April 8, 2014, to respond to the Complaint.

PURSUANT TO STIPULATION, IT IS SO ORDERED.