STIPULATION TO EXTEND CLASS CERTIFICATION DEADLINES FOR THE OPPOSITION AND REPLY AND DECLARATION OF LAURIE E. SHERWOOD (LOCAL RULE 6-2); ORDER;

HAYWOOD S. GILLIAM, Jr., District Judge.

1. On September 12, 2014, the parties agreed to a 90 day continuance of the filing deadlines and hearing date on plaintiff's motion for class certification to allow for the parties to participate in a settlement conference with Magistrate Judge Kandis Westmore and to conduct discovery following the settlement conference. On September 15, 2015, Judge Edward Chen executed the order, and indicated that no further continuance would be granted. The order set the following schedule:

2. On December 1, 2015, the parties participated in a settlement conference with Magistrate Judge Westmore. The matter did not settle but counsel for all parties have continued to communicate with Magistrate Judge Westmore, and continue to explore possible resolution of the case.

3. On March 13, 2015, plaintiff filed her motion for class certification. On March 31, 2015, defendants deposed plaintiff Jamie Mendez. The deposition raised facts requiring additional investigation by defendant C-Two Group, Inc. Additionally, one of C-Two Group, Inc.'s witnesses is out of the country and will not return until next week.

4. In light of the above and to continue settlement discussions, the parties have agreed, subject to court approval, to a two week extension to file the opposition and reply. The parties do not seek to continue the hearing date of May 28, 2015, on Plaintiff's Motion for Class Certification.

IT IS THEREFORE STIPULATED by and between Plaintiff and Defendants, through their respective counsel, and subject to Court approval, as follows:

1. The deadline to file Defendants' Opposition to Plaintiffs' Motion for Class Certification is extended from April 10, 2015, to April 24, 2015;

2. The deadline to file Plaintiffs' Reply to Defendants' Opposition to Plaintiff's Motion for Class Certification is extended from May 1, 2015, to May 15, 2015; and

3. The hearing date on Plaintiff's Motion for Class Certification will not be continued and will remain on May 28, 2015.

IT IS SO STIPULATED:

DECLARATION OF LAURIE E. SHERWOOD

1. I am an attorney at law, duly licensed to practice in the State of California and a partner with the firm of Walsworth, Franklin, Bevins & McCall, LLP, counsel of record for defendant C-Two Group, Inc. I have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could and would testify competently to such facts under oath.

2. On September 12, 2014, the parties agreed to a 90 day continuance of the filing deadlines and hearing date on plaintiff's motion for class certification to allow for the parties to participate in a settlement conference with Magistrate Judge Kandis Westmore and to conduct discovery following the settlement conference. On September 15, 2015, Judge Edward Chen executed the order, and indicated that no further continuance would be granted. The order set the following schedule:

3. On December 1, 2015, the parties participated in a settlement conference with Magistrate Judge Westmore. The matter did not settle but counsel for all parties have continued to communicate with Magistrate Judge Westmore, and continue to explore possible resolution of the case.

4. On March 13, 2015, plaintiff filed her motion for class certification. On March 31, 2015, defendants deposed plaintiff Jamie Mendez. The deposition raised facts requiring additional investigation by defendant C-Two Group, Inc. Additionally, one of C-Two Group, Inc.'s witnesses is out of the country and will not return until next week.

5. In light of the above and to continue settlement discussions, the parties have agreed, subject to court approval, to a two week extension to file the opposition and reply. The parties do not seek to continue the hearing date of May 28, 2015, on Plaintiff's Motion for Class Certification. The requested extension will not affect the case schedule.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed on this 8th day of April, 2015, at San Francisco, California.

ORDER

IT IS ORDERED as follows:

1. The deadline to file Defendants' Opposition to Plaintiffs' Motion for Class Certification is extended from April 10, 2015, to April 24, 2015;

2. The deadline to file Plaintiffs' Reply to Defendants' Opposition to Plaintiff's Motion for Class Certification is extended from May 1, 2015, to May 15, 2015; and

3. The hearing date on Plaintiff's Motion for Class Certification will not be continued and will remain on May 28, 2015.