STIPULATION AND [PROPOSED] ORDER (1) TO CONTINUE CASE MANAGEMENT CONFERENCE AND (2) TO MODIFY BRIEFING DEADLINES RELATED TO DEFENDANTS' MOTIONS IN RESPONSE TO PLAINTIFF'S SECOND AMENDED COMPLAINT; DECLARATION OF MICHAEL J. STORTZ IN SUPPORT

VINCE CHHABRIA, District Judge.

Pursuant to Civil Local Rule 6-1(b), the parties through counsel have met and conferred and reached agreement, as follows.

WHEREAS, after convening for a Case Management Conference on September 30, 2014, the Court issued a Minute Order (D.E. 36) requiring the parties to participate in a Settlement Conference before Magistrate Judge Joseph C. Spero, and scheduling a further Case Management Conference for January 22, 2015;

WHEREAS, the Settlement Conference is currently scheduled for December 10, 2014, pursuant to the Settlement Conference Order issued by Judge Spero (D.E. 37);

WHEREAS, in light of the discussion at the September 30, 2014 Case Management Conference, Defendants plan to file, on or before October 31, 2014, a Motion to Dismiss Plaintiff's Second Amended Complaint (SAC), and a Motion to Strike the putative class allegations based on lack of numerosity;

WHEREAS, Plaintiff anticipates deposing one or more witnesses identified in Defendants' Motion to Strike, and seeks adequate time to take those depositions prior to filing her Opposition to said Motion;

WHEREAS, the parties have met and conferred and have agreed to a briefing and hearing schedule for these two Motions that allows for deposition discovery and further briefing to occur after the December 10, 2014 Settlement Conference, as set forth below.

THEREFORE, IT IS HEREBY STIPULATED by the parties through their respective counsel, subject to Court approval, as follows:

1. Defendants shall have to and including October 31, 2014 to file their: (a) Motion to Dismiss Plaintiff's SAC; and (b) Motion to Strike the putative class allegations in Plaintiff's SAC.

2. Plaintiff shall have to and including January 22, 2015 to file papers in opposition.

3. Defendants shall have to and including February 12, 2015 to file papers in reply.

4. The hearing on Defendants' Motions shall be set for February 26, 2015 at 10:00 a.m.

5. The Case Management Conference currently scheduled for January 22, 2015 shall be continued to March 10, 2015 at 10:00 a.m.

6. The deadline for the parties to file an updated Joint Case Management Statement shall be continued to and including March 3, 2015.

IT IS SO STIPULATED.

Attestation Pursuant to Civil Local Rule 5-1(i)

Pursuant to Civil Local Rule 5-1(i), I, Michael J. Stortz, hereby attest that I have obtained concurrence in the filing of this document from the other signatory to this document.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 10th day of October, 2014 in San Francisco, California.

PURSUANT TO STIPULATION, IT IS SO ORDERED.