STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AS MODIFIED

VINCE CHHABRIA, District Judge.

Pursuant to Local Rule 6-1(a), the parties hereby provide notice of their stipulation to continue the Case Management Conference currently set for January 20, 2015.

WHEREAS, Plaintiff filed his Class Action Complaint in this matter on June 12, 2014;

WHEREAS, Plaintiff filed his First Amended Class Action Complaint in this matter on August 7, 2014;

WHEREAS, Defendant timely filed its Motion to Dismiss Plaintiff's First Amended Class Action Complaint in this matter on September 11, 2014;

WHEREAS, a hearing was held on Defendant's Motion to Dismiss Plaintiff's First Amended Class Action Complaint on November 6, 2014. The Court granted Defendant's Motion to Dismiss, giving Plaintiff leave to amend;

WHEREAS, on November 10, 2014, the parties stipulated to continue the deadline for Plaintiff to file his Second Amended Complaint ("SAC") and the deadline for Defendant to respond to the SAC. On November 12, 2014, the Court granted the parties' stipulation, giving Plaintiff until December 11, 2014 to file his SAC, and giving Defendant until January 15, 2015 to file its response to the SAC;

WHEREAS, on December 5, 2014, the Court granted the parties stipulation to reset the Case Management Conference to January 20, 2015;

WHEREAS, on December 11, 2014, Plaintiff filed his SAC;

WHEREAS, Defendant anticipates filing a Motion to Dismiss the SAC, set to be heard on February 19, 2015;

WHEREAS, given the pending Motion practice on the pleadings, the Parties, upon meeting and conferring, have agreed that pleadings issues should be resolved prior to the Case Management Conference. Accordingly, the Parties have agreed that good cause exists to continue the Case Management Conference from January 20, 2015 to and including February 19, 2015 at 10:00 a.m. The Parties have further agreed that good cause exists to continue to the deadline to submit a Joint Case Management Conference Report to February 12, 2015.

NOW THEREFORE, THE PARTIES STIPULATE THAT:

1. The Case Management Conference previously set for January 20, 2015 shall be continued to February 19, 2015 at 10:00 a.m.

2. The Parties shall file a Joint Case Management Conference Report on or before February 12, 2015.

IT IS SO STIPULATED.

[PROPOSED] ORDER

PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS SO ORDERED. THE CASE MANAGEMENT CONFERENCE STATEMENT SHALL BE DUE ON March 3 ________, 2015. THE CASE MANAGEMENT CONFERENCE SHALL BE HELD ON

IT IS SO ORDERED AS MODIFIED.