STIPULATION AND [PROPOSED] ORDER REGARDING CLASS CERTIFICATION DISCOVERY CUTOFF AND CLASS CERTIFICATION BRIEFING SCHEDULE

VINCE CHHABRIA, District Judge.

The undersigned parties, by and through their respective counsel, do hereby stipulate:

WHEREAS, pursuant to the Court's Amended Case Management Order (Dkt. No. 110), the current deadline for completing discovery related to class certification is September 24, 2015;

WHEREAS, pursuant to the parties' stipulation and subsequent Court Order (Dkt. No. 136), Plaintiffs are to file their Motion for Class Certification on October 8, 2015, Defendant is to file its Opposition thereto on November 17, 2015, and Plaintiffs are to file their Reply on December 3, 2015;

WHEREAS, the parties have engaged in two settlement conferences to date and are scheduled to engage in their third settlement conference on October 13, 2015, five days after Plaintiffs are currently scheduled to file their Motion for Class Certification (Dkt. No. 150);

WHEREAS, the parties agree that it would be beneficial to focus their time and resources on this settlement conference;

WHEREAS, Defendant requires substantial additional time to supplement its previous production of documents in response to Plaintiffs' Requests for Production of Documents in advance of the deposition(s) of Defendant's Fed. R. Civ. P. 30(b)(6) designee(s);

WHEREAS, Plaintiffs require that Defendant complete its supplemental document production in advance of taking Defendant's deposition(s) and in advance of filing their Motion for Class Certification;

IT IS HEREBY STIPULATED, by and between Plaintiffs and Defendant, by and through their respective counsel, that:

1. The deadline to complete discovery related to class certification shall be Friday, November 20, 2015.

2. Plaintiffs shall file their Motion for Class Certification on Tuesday, December 8, 2015.

3. Defendant shall file their Opposition to Plaintiffs' Motion for Class Certification on Tuesday, January 19, 2016.

4. Plaintiffs shall file their Reply in Support of their Motion for Class Certification on Tuesday, February 9, 2016.

5. A hearing on Plaintiffs' Motion for Class Certification shall be held on Thursday, February 25, 2016.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.