JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO THE COMPLAINT AND CONTINUING CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES

RICHARD SEEBORG, District Judge.

Pursuant to Local Rule 6-2, Plaintiff Nancie Ligon ("Plaintiff) and Defendant L'Oréal USA, Inc. ("L'Oréal or Defendant") hereby submit, through the undersigned, the following Joint Stipulation requesting a further extension of time for L'Oréal to respond the complaint and continuing for approximately 30 days the scheduled initial Case Management Conference and related deadlines.

WHEREAS on August 30, 2012, Plaintiff filed her complaint in the above-titled action in the United States District Court, Northern District of California;

WHEREAS on September 6, 2012, Plaintiff served her complaint on Defendant;

WHEREAS Defendant's responsive pleading deadline was originally September 27, 2012, but was extended by stipulation to November 16, 2012;

WHEREAS on October 15, 2012, the Court ordered a CMC to take place on January 17, 2013 at 10:00 a.m.;

WHEREAS on October 25, 2012, pursuant to stipulation, the Court further extended L'Oréal's response deadline to January 29, 2013 and continued the CMC date to February 21, 2013 to allow the parties time to engage in informal discovery and to discuss the claims and defenses;

WHEREAS the parties are still engaging in informal discovery on a confidential basis and analyzing and discussing claims and defenses and would like the time to complete this process before moving forward with litigation;

IT IS THEREFORE STIPULATED AND AGREED by and among Plaintiff and L'Oréal through the undersigned, to extend L'Oréal's responsive pleading deadline to March 1, 2013, to postpone the CMC until March 21, 2013 at 10:00 a.m., or until the first available date thereafter, and to continue all dates relating to the CMC accordingly.

SO STIPULATED:

PURSUANT TO STIPULATION, IT IS SO ORDERED.