STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT BY 30 DAYS (L.R. 6-1)

JACQUELINE SCOTT CORLEY, District Judge.

RECITATIONS AND STIPULATION

1. Plaintiffs Sherri Stewart and Gita Ighanian ("Plaintiffs") filed a complaint against AIRCOM International, Inc. ("AIRCOM"), Ericsson Communications, Inc., and Dixie De La Rosa on July 26, 2012 in the Superior Court for the County of Alameda alleging claims under California wage and hour laws and regulations and the California Business and Professions Code. The case is titled Stewart, et al. v. AIRCOM International, Inc., et al., No. RG 12640926. On September 19, 2012, the Complaint was amended to add Ericsson, Inc. ("Ericsson") as a party to the case. The summons and complaint was served on Ericsson on or about October 17, 2012. AIRCOM accepted service of the summons and complaint on November 12, 2012. Neither Ericsson Communications, Inc. nor Dixie De La Rosa have been served.

2. On December 11, 2012, AIRCOM filed a Notice of Removal in the state court action and removed the case to federal court. Under Federal Rule of Civil Procedure 81(c)(2), AIRCOM and Ericsson's responsive pleading is currently due December 18, 2012 — 7 days after removal.

3. On December 13, 2012, counsel for both parties met and conferred extensively in good faith pursuant to Central District Local Rule 1-5(n) regarding Defendant's anticipated motion to dismiss and/or strike under Federal Rule of Civil Procedure 12(b)(6) and are still in discussions regarding the same.

4. In furtherance of the spirit of Local Rule 1-5(n) and to narrow any motions to only those issues in dispute, the parties hereby stipulated to extend the time for AIRCOM and Ericsson to respond to the initial complaint for 30 days, up to January 17, 2013 pursuant to Local Rule 6-1 to allow time for the Parties to enter into further stipulations regarding Plaintiffs' amended complaint (if any), and the briefing schedule for AIRCOM and Ericsson's motion to dismiss (if any).