STIPULATION FOR EXTENSION OF EXPERT AND CLASS CERTIFICATION DEADLINES AND PROPOSED ORDER

THELTON E. HENDERSON, District Judge.

Pursuant to Local Rules 6-2 and 7-12, Plaintiffs Shawn Heaton and Anna Ahlborn ("Plaintiffs") and Defendants Social Finance, Inc. and SoFi Lending Corp. ("Defendants") (collectively the "parties"), by and through their undersigned counsel, hereby stipulate and agree as follows:

WHEREAS, Plaintiffs have made numerous discovery requests for documents and other materials from Defendant;

WHEREAS, Plaintiffs made some of the discovery requests that are pertinent to this Stipulation as early as February 18, 2015 and made the latest of the requests on December 16, 2015;

WHEREAS Plaintiffs have met and conferred with Defendants about the timing of Defendants' responses to Plaintiffs' requests on several occasions;

WHEREAS Defendants have previously agreed to produce the information sought by Plaintiffs and set forth in the Declaration of E. Michelle Drake, and represented to the Court that such production would be forthcoming, but have been unable to make a production to date;

WHEREAS it has proven to be more difficult that Defendants' counsel anticipated to retrieve information responsive to Plaintiffs' request than Defendants' counsel believed when the parties discussed scheduling deadlines with the Court on November 2, 2015;

WHEREAS Plaintiffs acknowledge that Defendants have made a good faith effort to produce the requested information but, due to unanticipated difficulties, have been unable to do so;

WHEREAS the parties agree that the as-yet unproduced discovery may be relevant to the parties' expert reports for purposes of class certification and to Plaintiffs' forthcoming motion for class certification;

WHEREAS one of Plaintiffs discovery requests (involving search terms) has returned a voluminous number of documents and the parties have already met and conferred once and agreed to further meet and confer regarding limiting some of those terms so as to facilitate production by February 12, 2016;

WHEREAS Defendant has agreed to produce the information Plaintiffs seek on or before February 12, 2016;

WHEREAS Defendants' anticipated production includes web pages from the SoFi.com website as well as communications reflecting possible user complaints about "hard" credit pulls;

WHEREAS Plaintiffs have already noticed and intend to take at least two depositions after receiving and reviewing this information;

WHEREAS Plaintiffs will need to review and code the information after it is received and will subsequently need to provide the information to their class certification expert;

WHEREAS, Plaintiffs anticipate that the depositions, the document review process, consultation with Plaintiffs' experts, and preparation of an expert report will require a minimum total of 45 days;

WHEREAS the parties intend to mediate this case before Judge Infante on January 26, 2016;

WHEREAS this request for enlargement is further supported by detailed reasons contained in the Declarations of E. Michelle Drake and James F. McCabe;

WHEREAS the parties previously sought an extension of the deadline for Plaintiffs to file an amended complaint (ECF No. 44) but this is the parties' first request for an extension of these deadlines;

WHEREAS an extension of these deadlines will not affect any other deadlines in the case as the Court's scheduling order extends only through the completion of briefing on Plaintiffs' motion for class certification (ECF No. 95);

WHEREFORE, the parties respectfully request the Court extend the following deadlines as set forth below.

ATTESTATION

I, James F. McCabe, am the ECF User whose ID and password are being used to file this document. In compliance with Civil L.R. 5-1(i)(3), I hereby attest that E. MICHELLE DRAKE concurs in this filing.

PURSUANT TO STIPULATION, IT IS SO ORDERED.