JOINT STIPULATION TO CONTINUE REMAINING FILING DEADLINES AND HEARING ON DEFENDANTS' MOTION TO DISMISS FIRST AMENDED COMPLAINT PENDING POTENTIAL CASE CONSOLIDATION; [PROPOSED] ORDER

SAUNDRA BROWN ARMSTRONG, District Judge.

Pursuant to Civil L.R. 6-1(b), Plaintiffs Jessica Morales, Berenisa Cortes Palominos, Dylan Thomas and Frances Handcock ("Plaintiffs") and Defendants Von Curtis, Inc., P.M. Advanced Education Inc., Paul Mitchell Advanced Education LLC, John Paul Mitchell Systems, PMNV Las Vegas, LLC, PMCA Bakersfield, LLC, PMHBW LLC, Winn Claybaugh, John Paul DeJoria, Paul Mantea, D'Ann Evans, and Ann-Marie Safadi (collectively "Defendants")1 hereby stipulate and agree as follows:

RECITALS

WHEREAS, on June 13, 2014, Defendants filed a Motion to Dismiss Plaintiffs' First Amended Complaint, which is scheduled to be heard by the Court on July 29, 2014, at 1:00 p.m.;

WHEREAS, Plaintiffs' opposition to Defendants' Motion to Dismiss is due on June 27, 2014, and Defendants' reply brief in support of their Motion to Dismiss is due on July 7, 2014;

WHEREAS, a class action entitled Gerard et al, v. John Paul Mitchell Systems et al. was filed on April 22, 2014, in the Superior Court of Los Angeles County, case number BC543275 (the "Gerard" case), alleging causes of action against one of the Defendants in this action, John Paul Mitchell Systems ("JPMS"), as well as "John Paul Mitchell the School," for failure to pay minimum wage and overtime wages under California law and the federal Fair Labor Standards Act, failure to provide meal breaks and rest breaks under California law, failure to provide accurate wage statements under California law, failure to timely pay all earned wages due at time of separation under California law, unfair business practices under California law, unjust enrichment, and civil penalties pursuant to the California Private Attorneys General Act;

WHEREAS, JPMS removed the Gerard case to the U.S. District Court, Central District of California on June 26, 2014;

WHEREAS, on June 26, 2014, the parties' counsel met and conferred regarding similarities between the two cases and the potential consolidation of the two cases;

WHEREAS, the parties hereby stipulate to continue the opposition due date, the reply due date, and the hearing on Defendants' Motion to Dismiss pending resolution of the consolidation of the two lawsuits;

WHEREAS, the parties hereby stipulate and agree that nothing herein affects the timeliness of Defendants' response to this lawsuit.

IT IS HEREBY STIPULATED by and between Plaintiffs, on the one hand, and Defendants, on the other, through their respective counsel of record, that Plaintiffs' deadline to respond to Defendants' Motion to Dismiss shall be continued to at least twenty-one (21) days after the Court issues an order granting, denying or otherwise resolving an anticipated request for consolidation of this case and the Gerard case; that Defendants' deadline to file a reply brief shall be continued to seven (7) days after Plaintiffs' file any opposition brief; and that the hearing on Defendants' pending Motion to Dismiss the First Amended Complaint be continued to at least fourteen (14) days after Defendants file their reply brief.

ORDER

Pursuant to the stipulation, IT IS SO ORDERED.