JOINT STIPULATION AND ORDER FOR LEAVE TO FILE SECOND AMENDED COMPLAINT

HAYWOOD S. GILLIAM, Jr., District Judge.

Plaintiffs Damon Cardinalli, Robert Crandall, Rene Fragoso, Daniel Guerrero, Nishell Johnson, Daisy Larios, Shannon Law, Pauline Martinez, Jeffrey Monroy, Seng Saephan, Michael Santos, Sarah Scott, Ernesto Segovia, Robert Ramirez, Nickolas Ross, and Steven Girard ("Plaintiffs"), and Defendants Wireless Lifestyle, Inc. and Wireless Lifestyle, LLC ("Defendants"), by and through their attorneys of record, hereby stipulate and agree as follows:

WHEREAS, Plaintiffs filed their initial complaint on November 15, 2015;

WHEREAS, the parties stipulated on January 6, 2016, to Plaintiffs filing a First Amended Complaint primarily for purposes of alleging exhaustion of the administrative requirements pursuant to the Private Attorneys General Act ("PAGA"), which stipulation was granted by order dated January 13, 2016;

WHEREAS, Plaintiffs seek to add an additional Plaintiff, Steven Girard, to pursue claims for unfair business practices under California Business and Professionals Code Section 17200 based on unpaid overtime and meal break violations and unreimbursed business expenses, which claims are already set forth in the First Amended Complaint and are substantially the same as the other Plaintiffs' claims for unfair business practices under California Business and Professionals Code Section 17200;

WHEREAS, Plaintiffs also seek to add an additional Defendant, Wireless Lifestyle, LLC;

WHEREAS, the first Case Management Conference was held on March 1, 2016, where the parties discussed their plan to mediate the case on May 4;

WHEREAS no deadlines or trial date have yet been established in this case;

The Parties, through their undersigned representative counsel of record, hereby stipulate that Plaintiffs shall have leave to file a Second Amended Complaint in this lawsuit primarily for purposes of adding Plaintiff Steven Girard and Defendant Wireless Lifestyle, LLC. A copy of the Proposed Second Amended Complaint is attached heretoo as Exhibit A.

ECF ATTESTATION

Pursuant to Civil L.R. 5-1(i)(3), the filer attests that concurrence in the filing of this document has been obtained from each of the other signatoriies thereto.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.