STIPULATION AND [PROPOSED] ORDER REGARDING MODIFICATION TO DEADLINE TO FILE RESPONSIVE DECLARATION REGARDING MOTION TO SEAL REPLY IN SUPPORT OF CLASS CERTIFICATION BRIEF [N.D. CAL. L.R. 7-11]

EDWARD M. CHEN, District Judge.

WHEREAS, Plaintiffs filed their thirty-five page reply in support of their motion for class certification on Monday, May 2, 2016, along with exhibits;

WHEREAS, Plaintiffs cited numerous documents in those papers that have been designated by Ford as Protected Documents pursuant to the protective order entered in this case (ECF No. 96), and made numerous assertions that are derived from such Protective Documents;

WHEREAS, pursuant to the Protective Order and Local Rule 79-5, Plaintiffs filed their papers as partially redacted so as not to disclose the contents of the Protected Documents, and filed a motion to seal the redacted information;

WHEREAS Ford is required to file a responsive declaration supporting the sealing of the Protected Documents or information derived therefrom in Plaintiffs' papers within four days after they are filed (see ECF No. 96 at 6);

WHEREAS, the number of the Protected Documents Plaintiffs cited in their papers, and the fact that the individual responsible for signing the declaration will be out of the office and unavailable on Thursday, May 5 and Friday, May 6 make it impractical to finish the declaration by Friday, May 6, despite best efforts;

WHEREAS, Ford requires an extension of three business days in order to complete its responsive declaration;

WHEREAS, Local Rule 7-11 permits a party to seek miscellaneous administrative relief pursuant to a stipulation by the parties;

WHEREAS, the deadline extension stipulated to by Ford and Plaintiffs will require no change to the dates set for trial of the matter;

WHEREAS, execution of this Stipulation is not a waiver of any claims or defenses Plaintiffs or Ford otherwise may have;

THEREFORE, IT IS HEREBY STIPULATED by Plaintiffs and Ford, through their counsel of record, subject to the approval of the Court, as follows:

1. The deadline for Ford to file a responsive declaration to establish that certain material in Plaintiffs' class certification reply papers is sealable is extended to

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.