STIPULATION AND [PROPOSED] ORDER REGARDING FURTHER MODIFICATION TO DEADLINE TO FILE RESPONSIVE DECLARATION REGARDING MOTION TO SEAL CLASS CERTIFICATION BRIEF

[N.D. CAL. L.R. 7-11]

EDWARD M. CHEN, District Judge.

WHEREAS, Plaintiffs filed their fifty page motion for class certification and memorandum of law in support thereof on Thursday, January 28, 2016;

WHEREAS, Plaintiffs cited numerous documents in their class certification papers that have been designated by Ford as Protected Documents pursuant to the protective order entered in this case (ECF No. 96), and made numerous assertions that are derived from such Protective Documents;

WHEREAS, pursuant to the Protective Order and Local Rule 79-5, Plaintiffs filed their papers as partially redacted so as not to disclose the contents of the Protected Documents, and filed a motion to seal the redacted information;

WHEREAS, pursuant to stipulation entered by this Court, Ford is required to file a responsive declaration supporting the sealing of the Protected Documents or information derived therefrom in Plaintiffs' papers by February 5, 2016 (see ECF No. 207);

WHEREAS, Plaintiffs had not yet filed their class certification papers at the time the prior stipulation was filed;

WHEREAS, Ford has been diligently working on drafting its responsive declaration, but the breadth of the Protected Documents Plaintiffs cited in their papers has proven to make it impractical to finish the declaration by February 5, despite best efforts;

WHEREAS, Ford requires an extension of two business days in order to complete its responsive declaration;

WHEREAS, Local Rule 7-11 permits a party to seek miscellaneous administrative relief pursuant to a stipulation by the parties;

WHEREAS, the deadline extension stipulated to by Ford and Plaintiffs will require no change to the dates set for trial of the matter;

WHEREAS, execution of this Stipulation is not a waiver of any claims or defenses Plaintiffs or Ford otherwise may have;

THEREFORE, IT IS HEREBY STIPULATED by Plaintiffs and Ford, through their counsel of record, subject to the approval of the Court, as follows:

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.