JOINT STIPULATION AND [PROPOSED] ORDER TO TRANSFER AND ALLOW LEAVE TO AMEND, AS MODIFIED BY THE COURT

PHYLLIS J. HAMILTON, Chief District Judge.

JOINT STIPULATION

Pursuant to Civil Local Rule 7-12, and subject to the Court's approval, Plaintiff TAMRYN SPRUILL ("Plaintiff") and Defendant VOX MEDIA, INC. ("Defendant"), through their respective attorneys, stipulate as follows:

WHEREAS, Plaintiff filed a complaint in this action in the Superior Court of the State of California in Alameda County on September 21, 2018 in Spruill v. Vox Media, Inc., No. 18921742;

WHEREAS, Defendant filed a notice of removal to the United States District Court, Northern District of California on November 9, 2018, ECF No. 1;

WHEREAS, shortly thereafter, on November 16, 2018, Defendant filed a Motion to Dismiss, Stay, or Transfer Proceedings ECF No. 11, seeking the dismissal or stay of this matter or, in the alternative, transfer for coordination with the case of Bradley v. Vox Media, Inc., No. 1:17-cv-01791 (D.D.C.), which has been pending for more than a year, on the ground that because the parties and issues in this case are substantially similar to those in Bradley, application of the first-to-file rule would avoid the risk of inconsistent decisions and would conserve judicial and litigant resources;

WHEREAS, Plaintiff filed a motion to remand the proceedings to Alameda Superior Court on December 5, 2018, ECF No. 23;

WHEREAS, in accordance with the schedule ordered by the Court, ECF No. 25, Defendant filed an opposition to the motion to remand on January 4, 2019, ECF No. 26;

WHEREAS, Plaintiff now agrees that federal jurisdiction under the Class Action Fairness Act of 2005 is proper and will file a notice of withdrawal of the motion to remand within 48 hours of entry of this stipulation;

WHEREAS, the parties now agree that transfer of this matter to the U.S. District Court for the District of Columbia for coordination with the Bradley case is in the interests of the parties and the Court given the substantial overlap between the cases; and

WHEREAS, Plaintiff has indicated that she intends to amend her complaint to, among other things, add a claim under the California Private Attorney General Act, Cal. Labor Code § 2699.

NOW, THEREFORE, IT IS AGREED:

1. Within 48 hours of entry of this stipulation, Plaintiff shall file a notice withdrawing her motion to remand in compliance with Local Civil Rule 7-7;

2. This case shall be transferred to the United States District Court for the District of Columbia, where the Parties agree that coordination with Bradley v. Vox Media, Inc., No. 1:17-cv-01791 (D.D.C.) is appropriate;

3. Plaintiff shall have 30 days from issuance of notice that the case has been received by the District Court for the District of Columbia to file an amended complaint.

DECLARATION OF FILER PURSUANT TO CIVIL LOCAL RULE 5-1(i)

Pursuant to Local Rule 5-1(i), the filer attests that the concurrence in the filing of this document has been obtained from each of the signatories.

[PROPOSED] ORDER, AS MODIFIED BY THE COURT

PURSUANT TO THE FOREGOING STIPULATION AND FOR GOOD CAUSE SHOWN, IT IS HEREBY ORDERED: