STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE AND HEARING DATE ON MOTION TO DISMISS AND REQUEST FOR JUDICIAL NOTICE AND ADJOURNING INITIAL CASE MANAGEMENT CONFERENCE

Civil L.R. 6-2

THELTON E. HENDERSON, District Judge.

Pursuant to Civil L.R. 6-2, Plaintiffs Nancy Coe, Tori Castro, and Pamela Mizzi (collectively, "Plaintiffs") and Defendant General Mills, Inc. ("Defendant") (collectively, Plaintiffs and Defendant are the "Parties"), by and through their undersigned counsel, stipulate as follows, subject to an order approving the stipulation:

WHEREAS, Defendant received service of Plaintiffs' Complaint on November 12, 2015;

WHEREAS, on December 3, 2015, the Parties filed a stipulation and proposed order that extended the deadline for Defendant to file a response to Plaintiffs' Complaint to January 15, 2016, and proposed a briefing schedule and hearing date on Defendant's anticipated motion to dismiss (Stip. & Proposed Order Regarding Mot. Briefing & Hr'g Schedule, ECF No. 17);

WHEREAS, on December 7, 2015, the Court so ordered the December 3, 2015, stipulation (Stip. & Order Regarding Mot. Briefing & Hr'g Schedule, ECF No. 18);

WHEREAS, on January 13, 2016, the Parties filed a stipulation and proposed order that extended the deadline for Defendant to respond to Plaintiffs' Complaint to January 29, 2016, extended the related briefing schedule, and continued the hearing date on Defendant's anticipated motion to dismiss (Stip. & Proposed Order Continuing Hr'g Date & Re-setting Briefing Schedule, ECF No. 20);

WHEREAS, on January 15, 2016, the Court so ordered the January 13, 2016, stipulation (Stip. & Order Continuing Hr'g Date & Re-setting Briefing Schedule, ECF No. 21);

WHEREAS, on January 29, 2016, Defendant filed a motion to dismiss Plaintiffs' Complaint (Def.'s Notice Mot. & Mot. Dismiss Compl., ECF No. 22), along with a supporting request for judicial notice (Def.'s Req. Judicial Notice Supp. Mot. Dismiss Compl., ECF No. 23);

WHEREAS, on December 9, 2015, the Court scheduled an Initial Case Management Conference for April 11, 2016, at 1:30 p.m. in Courtroom 12, 19th Floor, San Francisco, and set the deadline to file a Case Management Statement as April 4, 2016 (Clerk's Notice on Reassignment, ECF No. 19);

WHEREAS, due to recently arising scheduling conflicts and commitments of counsel, the Parties now seek a continuance of the previously-scheduled hearing date on Defendant's motion to dismiss and supporting request for judicial notice, and they wish to stipulate to an extension of the briefing schedule on those motions, as follows:

WHEREAS, the Parties also request that the Court adjourn the Initial Case Management Conference and the deadline for the Case Management Statement until after the Court enters a decision on Defendant's motion to dismiss;

WHEREAS, the Parties seek no other modifications to the schedule;

NOW, THEREFORE, pursuant to Civil L.R. 6-2, the Parties hereby stipulate and request that the Court enter an order setting the following briefing and hearing schedule on Defendant's motion to dismiss and accompanying request for judicial notice, if acceptable to the Court:

Additionally, pursuant to Civil L.R. 6-2, the Parties hereby stipulate and request that the Court enter an order adjourning the Initial Case Management Conference and the deadline for the Case Management Statement until after the Court enters a decision on Defendant's motion to dismiss.

The revisions to the hearing date and briefing schedule will not affect any other aspect of the schedule for the case.

ATTESTATION

Pursuant to Civil L.R. 5-1(i)(3), I hereby attest that I have on file written records documenting that I have obtained concurrence in the filing of this document from each of the other signatories.

[PROPOSED] ORDER

Pursuant to the foregoing stipulation, it is do ordered.