STIPULATION FOR AN EXTENSION OF TIME FOR PLAINTIFFS TO FILE THEIR THIRD 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, Defendant filed a motion to dismiss Plaintiffs' original Complaint pursuant to Federal Rule of Civil Procedure Rule 12(b)(6);

2. WHEREAS, this Court granted Defendant's motion to dismiss Plaintiffs' Complaint with leave to amend and ordered Plaintiffs to file their First Amended Complaint consistent with the Court's rulings by June 9, 2014 and to meet and confer regarding the sufficiency of Plaintiffs' amended allegations;

3. WHEREAS, the parties stipulated twice to continue the deadline to respond to Plaintiffs' First Amended Complaint to give the parties time to meaningfully meet and confer and to decide whether to participate in private mediation;

4. WHEREAS, Plaintiffs timely filed their Second Amended Complaint on July 17, 2014;

5. WHEREAS, the parties again stipulated twice to continue the deadline to August 27, 2014 for Defendant to respond to Plaintiffs' Second Amended Complaint or alternatively, for Plaintiffs to file a Third Amended Complaint, to give the parties time to meaningfully meet and confer with respect to Plaintiffs' amended allegations;

6. WHEREAS, based on the parties' meet and confer process, Plaintiffs have agreed to file a Third Amended Complaint;

7. WHEREAS, the Law Offices of Vincent M. Spohn are located in downtown Napa, California and sustained damage due to the recent earthquake;

8. WHEREAS, due to the damage sustained in the earthquake, the parties have agreed that Plaintiffs may file their Third Amended Complaint on Friday, August 29, 2014 and Defendant's deadline to file an Answer or otherwise respond to Plaintiffs' Third 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.

9. 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 to extend the deadline for Plaintiffs to file their Third Amended Complaint from August 27, 2014 to August 29, 2014 and Defendant's deadline to file an Answer or otherwise respond to Plaintiffs' Third 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 to extend the deadline for Plaintiffs' to file a Third Amended Complaint from August 27, 2014 to August 29, 2014 and the deadline for Defendant to file its Answer or otherwise respond to Plaintiffs' Third 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.