STIPULATION FOR A FURTHER EXTENSION OF TIME FOR DEFENDANTS' TO RESPOND TO THE FIRST AMENDED COMPLAINT AND [PROPOSED] ORDER

SAUNDRA B. ARMSTRONG, District Judge.

Plaintiffs Sandra Hatfield, Laurel Antonucci and Maureen Patricia Murphy ("Plaintiffs") and Defendant Renal Treatment Centers — California, Inc., erroneously sued as DaVita Healthcare Partners Inc. ("Defendant"), by and through its respective counsel of record, hereby stipulate and agree as follows:

1. WHEREAS, on June 24, 2014, the parties participated in a mediation session pursuant to the Northern District of California's Alternative Dispute Resolution Program, but did not settle the litigation.

2. WHEREAS, on June 26, 2014, in order to allow the parties the opportunity to meet and confer regarding the sufficiency Plaintiffs' amended allegations contained in Plaintiffs' First Amended Complaint, the parties stipulated to extend the deadline for Defendant to respond to Plaintiffs' First Amended Complaint to July 10, 2014; (2) to allow Plaintiffs to file a Second Amended Complaint by July 10, 2014 if they so choose following the parties' meet and confer; and (3) in the event Plaintiffs' file a Second Amended Complaint on July 10, 2014, Defendant's deadline to file an Answer or otherwise respond to Plaintiffs' Second Amended Complaint shall be in accordance with applicable Rules in the Federal Rules of Civil Procedure and/or the Northern District Court's Local Rules.

3. WHEREAS, the parties are contemplating participating in private mediation and wish to extend the July 10, 2014 deadline for one week to July 17, 2014 to give the parties time to decide whether to participate in private mediation.

4. WHEREAS, the parties' request is not made for the purpose of delay or any other improper purpose.

THEREFORE,

Pursuant to Rule 6-1(a) of the Local Rules of the United States District Court for the Northern District of California, the Parties hereby stipulate: (1) to extend the deadline for Defendant to respond to Plaintiffs' First Amended Complaint from July 10, 2014 to July 17, 2014 to give the parties time to decide whether to participate in private mediation; (2) to allow Plaintiffs to file a Second Amended Complaint by July 17, 2014; and (3) in the event Plaintiffs' file a Second Amended Complaint on July 17, 2014, Defendant's deadline to file an Answer or otherwise respond to Plaintiffs' Second Amended Complaint shall be in accordance with applicable Rules in the Federal Rules of Civil Procedure and/or the Northern District Court's Local Rules.

IT IS SO STIPULATED.

[PROPOSED] ORDER

The Court, having considered the Parties' stipulation, hereby grant the parties' request: (1) to extend the deadline for Defendant to respond to Plaintiffs' First Amended Complaint from July 10, 2014 to July 17, 2014 to give the parties time to decide whether to participate in private mediation; (2) to allow Plaintiffs to file a Second Amended Complaint by July 17, 2014; and (3) in the event Plaintiffs' file a Second Amended Complaint on July 17, 2014, Defendant's deadline to file an Answer or otherwise respond to Plaintiffs' Second Amended Complaint shall be in accordance with applicable Rules in the Federal Rules of Civil Procedure and/or the Northern District Court's Local Rules.

IT IS SO ORDERED.