JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE CLASS CERTIFICATION MOTION HEARING DATE

RICHARD SEEBORG, District Judge.

Plaintiff PAYAL PATEL ("Plaintiff") and Defendant NIKE RETAIL SERVICES, INC. ("Defendant") (collectively, the "Parties"), by and through their respective counsel, hereby stipulate as follows:

WHEREAS, Plaintiff filed a Motion for Class Certification on September 25, 2015 with seven declarations of putative class members, which was set to be heard on December 10, 2015;

WHEREAS, the Court recently granted the Parties' Second Stipulation to Extend Class Certification Opposition and Reply Deadlines in order to provide time for the completion of Defendant's declarant depositions setting the reply deadline as February 5, 2016 and the hearing date as March 10, 2016;

WHEREAS, Plaintiff, due to unavoidable unavailability on March 10, 2016, asked Defendant if the hearing date could be moved to accommodate Plaintiff's schedule, to which Defendant agreed;

WHEREAS, the next available date on which both Parties are available is March 24, 2016 at 1:30 p.m., or a date convenient for the Court's calendar thereafter;

WHEREAS, Plaintiff agrees that she will not seek additional discovery, including but not limited to written discovery or depositions, from the date of the filing of Plaintiff's reply brief, on February 5, 2016, until Plaintiff's class certification motion is heard.

WHEREAS, the Parties submit this stipulation in good faith and not for the purpose of delay or for any other improper purpose.

IT IS HEREBY STIPULATED.

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.