STIPULATION AND [PROPOSED] ORDER TO AMEND ANSWER AND NOTICE OF REMOVAL

JEFFREY S. WHITE, District Judge.

THIS STIPULATION is hereby entered into by and between Plaintiffs GAURAV PATHAK, SALAH DAJANI, ZANE HUSSEINI, NAVEED JALAL, DOLAN LONERGAN, WILLIAM MCRAE, MEUY XAIMUANGMONH, and LORD EL-SALAAM (collectively "Plaintiffs") and Defendants AVIS RENT A CAR SYSTEM, LLC; AB CAR RENTAL SERVICES, INC.; BUDGET RENT A CAR SYSTEM, INC.; AVIS BUDGET GROUP, INC., and MARIE PERAITA (collectively "Defendants") by through their authorized counsel, with respect to the following:

WHEREAS, Defendants filed an Answer to Plaintiffs' Unverified Complaint in the Superior Court of California, County of San Francisco, Case No. CGC-13-529903 on April 22, 2013 which inadvertently omitted reference to Defendant AVIS BUDGET GROUP, INC.;

WHEREAS, Defendants filed a Notice of Removal (Doc. #1) on April 24, 2013, incorporating by reference Defendants' Answer, which inadvertently omitted reference to Defendant AVIS BUDGET GROUP, INC.;

WHEREAS, the parties have discussed and agreed to the items listed below.

NOW, THEREFORE, IT IS HEREBY STIPULATED that:

1. Defendant AVIS BUDGET GROUP, INC. will be deemed to have joined in Defendants' Answer previously filed in California Superior Court and incorporated by reference in the Notice of Removal;

2. Defendant AVIS BUDGET GROUP, INC. will be deemed to have joined in the Defendants' Notice of Removal;

3. The Notice of Removal and Answer will be amended to reflect that each document was filed on behalf of Defendant AVIS BUDGET GROUP, INC.;

4. The Clerk of Court shall amend the docket to reflect this amendment; and

5. Nothing in this stipulation shall constitute a waiver of Plaintiffs' challenge to removal on the basis of subject-matter jurisdiction, currently before this Court as Plaintiffs' Motion for Remand (Doc. #11).

IT IS SO STIPULATED.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.