JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES

RICHARD SEEBORG, District Judge.

Pursuant to Local Rule 6-1 and 6-2, Plaintiff Kathie Sonner ("Plaintiff"), and Defendant Premier Nutrition Corporation ("Defendant"), through their respective counsel of record (collectively, "the Parties"), hereby stipulate and agree, subject to the Court's approval, as follows:

WHEREAS, the Parties have now exchanged the experts reports of six experts whose testimony will be used at class certification and summary judgment per the Court's Case Management Scheduling Order [ECF No. 66];

WHEREAS, the deadline to complete discovery of those experts is currently set for March 13, 2015 per the Court's Case Management Scheduling Order [ICF No. 66];

WHEREAS, with the benefit of the exchange of each Parties' expert reports, the Parties have agreed to renew settlement discussions at a mediation with Hon. Carl J. West (Ret.) at JAMS;

WHEREAS, the mediation is set for April 9, 2015, the earliest date practical given the Parties' and the mediator's schedule;

WHEREAS, the Parties seek a three-month extension of the expert discovery deadline so that they may postpone the depositions of their six experts and give the Parties time to focus their efforts on settlement;

WHEREAS, this request is made in good faith as an extension is necessary to allow the Parties sufficient time to prepare for and conduct a mediation and, then, complete expert discovery after the mediation (if the mediation proves unsuccessful);

WHEREAS, if this request is granted, it will be the fourth extension of case deadlines granted by the Court (the first extension was in connection with a stay of this case for an early mediation that proved unsuccessful, the second extension was requested because the Parties were unable to schedule key party depositions prior to discovery deadlines; and the third extension was in connection with Plaintiff's request to substitute the named plaintiff);

WHEREAS, this extension will not affect any pre-trial or trial dates as no dates have been set for trial;

WHEREAS, the requested extension, however, will affect the deadline to file opening memoranda in support of motions for summary judgment and class certification, which currently is set for May 8, 2015;

WHEREAS, the Parties also request that the deadline to file opening memoranda in support of motions for summary judgment and class certification be extended by three months, from May 8, 2015 to August 7, 2015; and,

WHEREAS, a Case Management Conference is scheduled to be held on March 19, 2015, at 10:00 am, and the Parties request that it be postponed until after the mediation scheduled for April 9, 2015.

NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties, through their respective counsel and subject to the Court's approval, that:

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.