[PROPOSED] ORDER

MARIA-ELENA JAMES, Magistrate Judge.

WHEREAS, Plaintiff filed the Complaint in this litigation on February 10, 2015;

WHEREAS, Defendant Target Corporation was served on February 23, 2015;

WHEREAS, a number of duplicative complaints were filed nationwide;

WHEREAS, a Motion for Consolidation and Transfer under 28 U.S.C. § 1407 was filed before the Judicial Panel on Multi-District Litigation ("JPML") to coordinate and/or consolidate all of the actions in one court;

WHEREAS, Plaintiff and Defendant Target Corporation expect that all of the actions will be coordinated and/or consolidated before one court;

WHEREAS, Plaintiff and Defendant Target Corporation wish to preserve the parties' and the Court's resources and efficiently manage the litigation so as not to cause prejudice;

WHEREAS, the parties have not previously requested any time modifications in this case;

WHEREAS, this stipulation would effect a stay of all deadlines in this case, including those contained in the Court's Order Setting Initial Case Management Conference and ADR Deadlines [ECF No. 4];

NOW THEREFORE, the parties agree as follows:

1. Defendant Target Corporation will not be required to answer or otherwise plead in response to the Complaint until after a scheduling order or briefing schedule is entered in a transferee court. In the event that the Motion for Consolidation and Transfer under 28 U.S.C. § 1407 is denied, the parties will confer within seven (7) days of the JPML's order regarding the due date for responsive pleadings in this action. No discovery shall be served in the above-captioned matter while this stipulation is in effect.

2. The deadlines established in the Court's Order Setting Initial Case Management Conference and ADR Deadlines [ECF No. 4] shall be stayed unless and until the Motion for Consolidation and Transfer under 28 U.S.C. § 1407 is denied. In the event that the Motion for Consolidation and Transfer under 28 U.S.C. § 1407 is denied, the parties will confer within seven (7) days of the JPML's order and submit to the court a stipulation proposing deadlines: (1) to meet and confer regarding initial disclosures, early settlement, ADR process selection and a discovery plan; (2) to file an ADR Certification signed by the parties; (3) to file either a stipulation to the ADR process or a Notice of Need for ADR Phone Conference; (4) to file a Rule 26(f) Report and complete initial disclosures or state objections in the Rule 26(f) report, and file a Case Management Statement; and (5) to hold the Initial Case Management Conference.

3. Defendant Target Corporation agrees that it will seek the same stipulation in any related action and, if it is unable to reach agreement, will file a motion to stay any related action before filing a responsive pleading in those related actions.

4. In the event that Defendant Target Corporation voluntarily files or is ordered to file a responsive pleading in any other related action prior to the JPML's decision, Defendant Target Corporation agrees that this stipulation will become void and in that event, all the parties agree to negotiate in good faith regarding a responsive pleading date.

PURSUANT TO STIPULATION, IT IS SO ORDERED.