RICHARD SEEBORG, District Judge.
Pursuant to Civil L.R. 6-1(b), 6-2, and 7-12, plaintiff Jamie Pettit and defendant The Procter & Gamble Company ("P&G") respectfully submit this joint stipulation to extend the current briefing schedule for class certification.
WHEREAS, at the August 13, 2015 Case Management Conference and in a subsequent order, this Court set the hearing for Plaintiff's Motion for Class Certification for May 5, 2016 and ordered that the Plaintiff shall file her opening brief on February 25, 2016, P&G shall file its opposition by March 28, 2016, and Plaintiff shall file her reply by April 14, 2016 [Dkt. No. 24];
WHEREAS, the parties have engaged in productive discovery, but believe more time to review that discovery would be useful before the parties brief class certification in this case;
WHEREAS, the parties agree it would be efficient to defer additional discovery and briefing in light of the court's order, in a similar case in which a plaintiff is challenging Charmin Freshmates flushable wipes (Belfiore v. Procter & Gamble Company, Case No. 14-cv-4090 (E.D.N.Y.) (Weinstein, J.)), that those parties participate in a settlement talks with Magistrate Judge Levy, which began on January 21 and are continuing on February 24, with additional talks possible thereafter.
WHEREAS, there have been no previous time modifications in this case;
WHEREAS, in light of the foregoing, Plaintiff and P&G request that the briefing schedule for Plaintiff's motion for class certification be continued approximately three months;
WHEREAS, the effect of the requested time modification will to be extend the current class certification briefing schedule approximately three months; and
WHEREAS, the parties have agreed that Plaintiff shall file her motion for class certification by May 19, 2016; P&G shall file its opposition by June 23, 2016; Plaintiff shall file her reply by July 14, 2016; and the hearing shall be held at 1:30 p.m. on August 4, 2016, or another date convenient for the Court;
NOW THEREFORE, THE PARTIES BY COUNSEL HEREBY STIPULATE:
Plaintiff shall file her motion for class certification by May 19, 2016; P&G shall file its opposition by June 23, 2016; Plaintiff shall file her reply by July 14, 2016; and the hearing shall be held at 1:30 p.m. on August 4, 2016, or another date convenient for the Court.