STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO PLAINTIFFS' SECOND AMENDED COMPLAINT

JEFFREY S. WHITE, Judge.

WHEREAS, on December 17, 2012, 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 (Docket No. 1);

WHEREAS, Plaintiffs filed their First Amended Class Action Complaint ("FAC") on February 4, 2013 (Docket No. 11);

WHEREAS, the Court granted a motion to dismiss the FAC with leave to amend (Docket No. 31);

WHEREAS, Plaintiffs prepared a Second Amended Class Action Complaint ("SAC") that included two additional claims and re-plead the claims that were the subject of the FAC, and on November 15, 2013, filed a motion for leave to amend to add the additional claims and attached the draft SAC;

WHEREAS, Defendants opposed the motion for leave to amend the SAC on grounds that the additional claims, as pled, were futile;

WHEREAS, on February 2, 2014, the Court granted the motion for leave to amend (Docket No. 41);

WHEREAS, pursuant to the Court's Order issued on February 2, 2014, Plaintiffs filed their SAC on February 11, 2014. (Docket No. 42);

WHEREAS, Defendants' response to the SAC currently is due on February 28, 2014;

WHEREAS, due to Defendants' counsel's vacation schedule and Defendants' need to evaluate the allegations, Plaintiffs have agreed to grant Defendants an extension of time to file their response to the SAC up to and including March 31, 2014;

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 to provide the Defendants with additional time to prepare their response due to Defendants' counsel's vacation schedule.

IT IS HEREBY STIPULATED by and between the parties, through their respective counsel of record that Defendants' response to the SAC shall be filed and served by March 31, 2014.

[PROPOSED] ORDER

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.