STIPULATION AND [PROPOSED] ORDER MODIFYING SCHEDULE FOR EXPERT DISCOVERY AND CLASS CERTIFICATION AS MODIFIED Civ. L.R. 6-2, 7-12

ELIZABETH D. LAPORTE, Magistrate Judge.

1. Plaintiff commenced this putative class action against defendants The Gillette Company and The Proctor and Gamble Company (collectively "Defendants") on April 10, 2012. Plaintiff alleges that Defendants violated California Business and Professions Code §§ 17200 et seq. and California Civil Code §§ 1750 et seq. with regard to product claims concerning Duracell Ultra Advanced and Duracell Ultra Power batteries. Defendants deny Plaintiff's claims have any merit.

2. On August 8, 2012, the Court issued its Case Management and Pretrial Order, setting, inter alia, deadlines for the exchange of expert reports and the completion of expert discovery regarding class certification and deadlines to file and brief the class certification motion. (Docket No. 25.)

3. The parties met and conferred pursuant to Rule 26(f) on July 9, 2012, and discovery commenced promptly thereafter. On July 12, 2012, Defendants served document requests and interrogatories on Plaintiff, and on July 20, 2012, Plaintiff served document requests and interrogatories on Defendants. On August 1, 2012, the parties exchanged initial disclosures, and on August 8, 2012, the Court issued its Case Management and Pretrial Order ("Case Management Order"). By stipulation among the parties, Plaintiff served responses and objections to Defendants' document requests and interrogatories on September 6, 2012, followed by supplemental responses and objections on October 22, 2012, and Defendants served responses and objections to Plaintiff's document requests and interrogatories on September 13, 2012.

4. On November 13, 2012, Plaintiff served his Second Set of Interrogatories to Defendant Gillette and also requested Defendants provide supplemental responses and clarifications to Plaintiff's First Set of Interrogatories. Gillette served responses and objections to Plaintiff's Second Set of Interrogatories on December 17, 2013. Defendants have agreed to provide supplemental responses and data to Plaintiff's First Set of Interrogatories no later than December 28, 2012.

5. On November 9, 2012, this Court ordered, pursuant to stipulation among the parties, that the deadlines in the Court's Case Management and Pretrial Order be reset (Docket No. 32). On December 19, 2012, after meeting and conferring with Defendants, Plaintiff filed a Motion for Administrative Relief Regarding Expert Discovery and Class Certification Scheduling, requesting the deadlines for expert discovery for class certification and the motion for class certification be extended.

6. After the parties further met and conferred on December 19, 2012 and in light of ongoing discovery being conducted by the parties, the parties agreed to a revised schedule for expert discovery and the motion for class certification. As part of this stipulation, Plaintiff agrees to withdraw his Motion for Administrative Relief.

7. The parties have agreed to the following proposed schedule:

8. Additionally, the parties have agreed that the deadlines for filing dispositive motions and the hearing on any dispositive motions (as set in the Court's August 8, 2012 order) should be reset to reflect this new schedule, as follows:

9. The parties believe that this proposed schedule will ensure the efficient, orderly, and complete litigation of expert discovery and class certification issues raised in this action.

[PROPOSED] ORDER

The Court, having considered the above stipulation of the parties, and good cause appearing therefore, HEREBY ORDERS THAT: 1. The schedule for expert discovery relating to class certification and Plaintiff's motion for Class Certification set in this Court's November 9, 2012 Order is modified as follows:

2. The schedule for filing dispositive motions and the hearing on any dispositive motions set in this Court's August 8, 2012 Order is modified as follows:

PURSUANT TO STIPULATION, IT IS SO ORDERED.