STIPULATED MOTION TO SET NEW DISCOVERY DEADLINES IN LIGHT OF PENDING MEDIATION AND ORDER

MORRISON C. ENGLAND, JR., District Judge.

Plaintiffs Eugenio and Rosa Contreras, William Phillips, Teresa Barney, Keith and Teresa Marcel, Sherlie Charlot, Jennie Miller, and Edwin Yager, on behalf of themselves and all others similarly situated ("Plaintiffs") and Defendants Nationstar Mortgage LLC and Solutionstar Field Services LLC (erroneously sued herein as Solutionstar LLC (n/k/a Xome Holding LLC)) LLC (collectively "Nationstar") (together, the "Parties") by and through their respective counsel of record, hereby submit this Stipulated Motion To Extend Discovery Deadlines in Light of Pending Mediation as set forth below.

Pursuant to the Parties' Joint Report Under Rule 26 of the Federal Rules of Civil Procedure, November 17, 2017, ECF No. 30, at § XI, the parties have determined that settlement discussions in this matter are no longer premature, and they have engaged the services of JAMS mediator the Hon. Ronald M. Sabraw (Ret.) to assist them in working to resolve this matter. The parties will conduct a mediation with Hon. Sabraw on Thursday, October 10, 2019.

To avoid incurring the costs of fact and expert discovery while simultaneously engaging in settlement negotiations, the parties request that the Court extend all deadlines on pending party discovery and class certification briefing. Following conclusion of the mediation process, the parties will promptly file a notice with the Court informing it of the outcome and either request a schedule for filing settlement papers or an order resuming discovery. The parties agree that during the mediation process they will only seek discovery necessary for resolution of the matter and this agreement to limit discovery will also extend to ongoing document production from third parties based on previously served subpoenas.

To make up for the time spent choosing a mediator, preparing for and participating in initial meetings with the mediator, and conducting the mediation itself, the parties request that the case deadlines for class certification briefing and fact and expert discovery be extended by approximately 110 days from the dates contained in the Stipulated Motion and Order Extending Case Schedule (ECF No. 85). The parties further request that ancillary deadlines relating to fact and expert discovery for class certification be modified to better align with the parties' extended class certification briefing deadlines.

This Stipulation is the fourth extension of certain deadlines on the case schedule and is made with good cause and without prejudice to, or waiver of, any rights or defenses otherwise available to the Parties in this action. The Parties therefore respectfully request that the Court grant this Stipulated Motion to set new discovery deadlines by extending all briefing and fact and expert discovery deadlines by 110 days from the dates contained in the prior Stipulated Motion and Order Extending Case Schedule as follows:

ATTESTATION REGARDING SIGNATURES

I, Laura Gerber, attest that all signatories listed, and on whose behalf the filing is submitted, concur in the filing's content and have authorized the filing.

IT IS SO ORDERED.