STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO MOVE TO DISMISS PLAINTIFFS' COMPLAINT, SETTING BRIEFING SCHEDULE ON MOTION TO DISMISS, STAYING DISCOVERY AND CONTINUING CASE MANAGEMENT CONFERENCE

JEFFREY S. WHITE, District Judge.

WHEREAS, plaintiffs Andrew Bradshaw, Tanif Stephenson, Adam Corriveau and Jesell Gonzalez ("Plaintiffs") filed their Class Action Complaint for Equitable, Declaratory and Injunctive Relief and Damages For (1) Aiding and Abetting Fraud, (2) Mistake of Fact, (3) Unjust Enrichment, (4) Violations of the California Unfair Competition Law, and (5) Violations of the Oklahoma Consumer Protection Act ("Complaint") on December 17, 2012;

WHEREAS, on or about January 16, 2013, the Complaint was served on defendants SLM Corporation and Sallie Mae, Inc. ("Defendants");

WHEREAS, Plaintiffs filed their First Amended Class Action Complaint ("FAC") on February 4, 2013;

WHEREAS, on or about February 4, 2013, counsel for Defendants agreed to accept service of the FAC on behalf of Defendants;

WHEREAS, Defendants' response to the FAC currently is due on March 22, 2013;

WHEREAS, Plaintiffs have agreed to grant Defendants an extension of time to file a response to the FAC up to and including March 29, 2013;

WHEREAS, Defendants have notified Plaintiffs of their intent to file a Motion to Dismiss the FAC;

WHEREAS, the parties have agreed on a proposed briefing schedule for Defendants' Motion to Dismiss;

WHEREAS, a Case Management Conference is currently set for April 19, 2013;

WHEREAS, to conserve judicial resources, the parties have further agreed to stay discovery and other proceedings until after the hearing on the Motion to Dismiss;

WHEREAS, pursuant to Civil Local Rules 6-1(b) and 6-2, the parties may request an order changing a deadline that would extend deadlines set forth in the Local Rules or Federal Rules;

WHEREAS, this Stipulation is made in good faith and not for purposes of delay; and

WHEREAS, good cause exists for the foregoing modifications to the case schedule because it would promote judicial efficiency to stay discovery and to continue the Case Management Conference and the parties' submission of their Joint Case Management Statement until after the hearing on the motion to dismiss.

IT IS HEREBY STIPULATED by and between the parties, through their respective counsel of record, as follows:

(a) Defendants' Motion to Dismiss shall be filed and served by March 29, 2013;

(b) Plaintiffs' Opposition to the Motion to Dismiss shall be filed and served by May 3, 2013, and Defendants' Reply shall be filed and served by May 17, 2013;

(c) The date of the hearing on the Motion to Dismiss shall be May 24, 2013, at 9:00 a.m. in Courtroom 11;

(d) Pending a ruling on the Motion to Dismiss, all discovery shall be stayed;

(e) The Case Management Conference set for April 19, 2013 at 1:30 p.m. shall be continued to July 26, 2013, 2013 at 1:30 p.m.;

(f) The parties shall complete initial disclosures or state their objections and file their Rule 26(f) Report and Joint Case Management Statement on or before July 19, 2013.

[PROPOSED] ORDER

Pursuant to the stipulation, the Court adopts the proposed briefing schedule and continuation of the PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

case management conference. The hearing on will be held on May 31. 2013. The parties are admonished that future requests to alter briefing schedules shall be supported by a showing of good cause.