WILLIAM ORRICK, District Judge.
Plaintiff ASHLEY ARMSTRONG ("Plaintiff") and Defendant CONCENTRIX CORPORATION ("Defendant") (collectively referred to as the "Parties"), hereby submit the following Stipulation and [Proposed] Order requesting an extension of the briefing schedule for Plaintiffs' Motion For Conditional FLSA Collective Action Certification And Issuance Of Notice Pursuant To 29 U.S.C. § 216(b) based on the current pleadings.
WHEREAS, Plaintiff filed its Complaint on September 19, 2016 ("Complaint");
WHEREAS, Defendant's answer to Plaintiff's Complaint is due on or before October 25, 2016;
WHEREAS, the Parties have met and conferred regarding the briefing schedule for Plaintiff's Motion For Conditional FLSA Collective Action Certification And Issuance Of Notice Pursuant To 29 U.S.C. § 216(b), and good cause exists to extend the briefing schedule for Plaintiff's Motion pursuant to FRCP 6(b)(1) (A), due to a death in the family of defense counsel;
WHEREAS, the Parties have agreed to the following briefing schedule for Plaintiff's Class Certification Motion based on the current pleadings: 1) Defendant's Opposition is due by November 4, 2016; 2) Plaintiff's Reply must be filed by November 14, 2016; and 3) the hearing on class certification will remain on December 8, 2016; and
WHEREAS, this Stipulation is not entered into for purposes of delay or harassment, and the Parties would be significantly prejudiced if the Stipulation was not approved.
ACCORDINGLY, THE PARTIES HEREBY STIPULATE AND AGREE THAT: 1) Defendant's Opposition is now due by November 4, 2016; 2) Plaintiff's Reply is now due by November 14, 2016; and 3) the hearing on class certification will remain on December 8, 2016.
I, ELISA NADEAU, attest pursuant to Northern District Local Rule 5-1(i)(3) that all other signatories to this document, on whose behalf this filing is submitted, concur in the filing's content and have authorized this filing. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: October 17, 2016.
1) Defendant's Opposition must be filed by November 4, 2016;
2) Plaintiff's Reply must be filed by November 14, 2016; and
3) The hearing on class certification will be set for December 7, 2016.