JOINT STIPULATION TO CONTINUE CLASS CERTIFICATION BRIEFING SCHEDULE; [PROPOSED] ORDER

MARIA-ELENA JAMES, Magistrate Judge.

Plaintiffs Kimberly Roberts, Carneisha Forney and Laurie Mullen ("collectively "Plaintiffs") and Defendants TJ MAXX of CA, LLC, Marshalls of CA, LLC, and Homegoods, Inc. (collectively "Defendants") (collectively the "Parties"), by and through their counsel of record, hereby stipulate to continue the deadlines set for Plaintiffs' motion for class certification by five (5) months. Such deadline provides the Parties sufficient time to explore mediation and is necessary to prepare and file briefs on the issue of certification. The Parties enter into this joint stipulation with reference to the following facts:

RECITALS

WHEREAS, the briefing schedule for Plaintiff's motion for class certification is presently as follows:

WHEREAS, the Parties have agreed to engage the services of Michael Dickstein to assist in settlement negotiations of the above-captioned action;

WHEREAS, given Mr. Dickstein's availability, the earliest mediation date that the parties could secure was in April of 2016;

WHEREAS, presently mediation has been set for April 12, 2016;

WHEREAS, the Parties agree that, to permit sufficient time and allow the parties to devote their efforts and resources fully towards resolution and, if necessary, to permit both Parties sufficient time to complete certification discovery, the deadlines presently set as to Plaintiffs' motion for class certification should be extended by five (5) months;

WHEREAS, only one prior continuance of the certification schedule briefing schedule has been requested;

WHEREAS, neither party objects to the time modifications set forth below; and,

WHEREAS, counsel for both parties do not believe that the time modifications will cause unnecessary delay or conflict with any other scheduling matters affecting the case.

STIPULATION

NOW, THEREFORE, it is hereby stipulated by the Parties, through their respective counsel of record, that the Plaintiffs shall have an additional five (5) months in which to file their motion for class certification, and the Parties further submit following briefing schedule for said motion:

SIGNATURE ATTESTATION

In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this document has been obtained from the signatories on this e-filed document.

(PROPOSED) ORDER

After reviewing the Parties' Joint Stipulation to Continue Class Certification Briefing Schedule, and good cause appearing therefor,

IT IS HEREBY ORDERED that the Plaintiffs shall have an additional five (5) months in which to file their motion for class certification, and the briefing schedule for said motion is as follows: