JOINT STIPULATION TO CONTINUE MOTION FOR CLASS CERTIFICATION DEADLINE; [PROPOSED] ORDER

BARBARA A. McAULIFFE, Magistrate Judge.

TO THE COURT, ALL PARTIES, AND COUNSEL OF RECORD:

Plaintiffs DELORES HUMES and DIANE ABELLA, on behalf of the putative class ("Plaintiffs"), and Defendant FIRST STUDENT, INC. ("Defendant"), collectively "the Parties," by and through their counsel of record, HEREBY STIPULATE AND AGREE to a continuance of the deadline for Plaintiff's Motion for Class Certification ("motion") and related briefing schedule, as follows:

WHEREAS, on March 18, 2016, the Court issued a Preliminary Scheduling Order setting forth the briefing schedule for Plaintiffs' forthcoming motion for class certification;

WHEREAS, on August 17, 2016, the Parties stipulated to a revised briefing schedule regarding Plaintiffs' forthcoming motion for class certification, and the Court entered an Order adopting said revised briefing schedule on August 19, 2016;

WHEREAS, Plaintiffs served a First Set of Request for Production of Documents on May 6, 2016;

WHEREAS, Defendant responded to Plaintiffs' First Set of Request for Production for Documents on June 23, 2016;

WHEREAS, Plaintiffs sent a meet and confer letter concerning Defendant's responses to Plaintiffs' First Set of Production for Documents on August 1, 2016;

WHEREAS, Plaintiffs and Defendant then conferred a number of times regarding what documents Defendant would ultimately produce;

WHEREAS, Defendant informed Plaintiffs on October 12, 2016, that 37 bankers boxes of documents responsive to Plaintiff's First Set of Request for Production of Documents would be made available at an off-site facility in Hayward, California, beginning on October 24, 2016;

WHEREAS, Plaintiffs are in the process of engaging a copier and planning an inspection date(s) for the documents at the Hayward facility;

WHEREAS, Plaintiffs intend to use the documents at the Hayward facility as part of their prove-up for the motion for class certification;

WHEREAS, Plaintiffs' present deadline to move for class certification is November 18, 2016;

WHEREAS, Plaintiffs will require additional time between the document inspection date and the class certification motion deadline in order to meaningfully incorporate the information gleaned from said documents into their moving papers;

WHEREAS, no trial date has been set;

WHEREAS, this Stipulation will promote judicial economy and is in the interests of the Parties;

The Parties accordingly request that the briefing scheduling and hearing date for Plaintiffs' forthcoming motion for class certification be modified as follows:

IT IS SO STIPULATED.

[PROPOSED] ORDER

The Court, having considered the parties' Stipulation to Continue the Class Certification Deadlines, finds that good cause exists to continue the motion for class certification and related filings to the following dates:

IT IS SO ORDERED.