JOINT STIPULATION RE: CLASS CERTIFICATION DISCOVERY DEADLINES AND DEADLINE FOR CERTIFICATION HEARING AND [PROPOSED] ORDER

RICHARD SEEBORG, District Judge.

Plaintiff Pam Rolita Bean ("Plaintiff") and Defendant Hugo Boss Retail, Inc. ("Defendant") (collectively the "Parties"), hereby agree and stipulate through their respective counsel to the following:

The parties scheduled this matter for mediation before Michael Dickstein on October 28, 2014. The location of the mediation was to be Hugo Boss's headquarters in New York, New York in order to accommodate the pregnancy of Hugo Boss's Corporate Representative, whose authority was necessary to resolve the case. Due to the premature birth of the Corporate Representative's child, the mediation was canceled on or about October 22, 2014. Since it is necessary for Hugo Boss's Corporate Representative to be present at the mediation, the parties have rescheduled the mediation for January 27, 2015, again in New York. This date is confirmed with Mr. Dickstein. In light of the delayed mediation, the parties have agreed to request this Court to continue the deadlines in the Case Management Scheduling Order as follows:

WHEREAS, the deadline to complete class certification discovery is January 30, 2015 and this date would be continued to March 30, 2015;

WHEREAS the class certification hearing date is presently set for May 14, 2015 and this date would be continued to July 9, 2015;

So stipulated:

SO ORDERED