STIPULATION AND ORDER TO FURTHER EXTEND CLASS CERTIFICATION DEADLINES TO FACILITATE SETTLEMENT DISCUSSIONS

RICARDO S. MARTINEZ, Chief District Judge.

Plaintiffs Tamara Lohr and Ravikiran Sindogi ("Plaintiffs") and Defendant Nissan North America, Inc. ("NNA") (collectively, the "Parties") enter into this stipulation with reference to the following facts and recitals:

1. On March 28, 2019, the Parties had a productive all day private mediation before Hon. James L. Warren (Ret.) at JAMS in San Francisco.

2. Based on the Parties' progress, a second all day mediation session has been scheduled for May 23, 2019.

3. The Parties are coordinating discovery and class certification deadlines in this action with a companion case filed in the Northern District of California, Johnson v. Nissan N. Am., Inc.,

4. The Parties require additional time to continue mediation efforts before undertaking further work to complete discovery in anticipation of class certification briefing and in anticipation of the preparation of expert reports.

5. The Parties have agreed to extend the deadlines in this case and in Johnson, to accommodate resolution discussions.

6. The Parties have coordinated with counsel in Johnson and are seeking entry of a similar scheduling order. If this Court and the Johnson court approve these requests, then the two cases will remain on parallel tracks if a resolution is not reached. An extension of the deadlines in this matter, as reflected below, would facilitate settlement discussions and will not be unduly prejudicial to either party.

For these reasons, the Parties stipulate to extend the deadlines in this matter as set forth below and respectfully request that the Court enter an order accordingly:

I. ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.