STIPULATION AND APPLICATION FOR EXTENSION OF TIME RE FILING PLAINTIFF'S SECOND AMENDED COMPLAINT AND SETTING A BRIEFING SCHEDULE ON ANY MOTION TO DISMISS IN RESPONSE

MORRISON C. ENGLAND, JR., District Judge.

Plaintiff SHAWN ALGER, AS AN INDIVIDUAL AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED ("Plaintiff") and Defendant FCA US LLC, formerly known as CHRYSLER GROUP, LLC ("Defendant") (collectively the "Parties"), by and through their attorneys of record in this case, hereby stipulate and request that the Court approve the filing of a Second Amended Complaint ("SAC"), and a briefing schedule for Defendant's Motion to Dismiss the SAC, if any.

This stipulation and application for extension of time is based on the following facts:

WHEREAS, Plaintiff filed this action on or about February 15, 2018;

WHEREAS, Plaintiff filed a First Amended Complaint ("FAC") in this action on or about February 16, 2018;

WHEREAS, pursuant to Local Rule 144(a), the Parties stipulated to a twenty-eight (28) day extension of Defendant's time to respond to the FAC up to and including April 10, 2018;

WHEREAS, the Parties met and conferred on April 5, 2018 and April 6, 2018 regarding Plaintiff's CLRA claims contained in the FAC;

WHEREAS, the Parties agree that, subject to Court approval, there is good cause and efficiencies may be achieved for the parties and the Court by filing a SAC that addresses issues raised as part of the parties' meet and confer efforts. The parties also stipulate, agree and request the following deadline for answering the SAC in the event Defendant does not to file a Motion to Dismiss Plaintiff's SAC or, in the alternative, a briefing schedule in the event Defendant files a Motion to Dismiss Plaintiff's SAC.

NOW, THEREFORE, the Parties stipulate as follows:

ORDER

The Court, having considered the Stipulation and Application for Extension of Time submitted herewith, and good cause appearing, hereby enters the following order:

IT IS SO ORDERED.