CLASS ACTION

JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING TIME TO FILE RESPONSE TO AMENDED COMPLAINT

EDWARD M. CHEN, District Judge.

Plaintiff MICHAEL ROBEY, MOE ASGHARNIA and JAMES COMB Individually and On Behalf of a Class of Similarly Situated Individuals ("Plaintiffs"), and Defendant TOYOTA MOTOR SALES, U.S.A., INC. ("Defendant") (collectively the "Parties"), by and through their respective counsel, hereby stipulate as follows:

WHEREAS, Plaintiffs filed this putative class action complaint against Defendant in the Northern District of California, San Francisco Division, on December 16, 2016 (the "Complaint");

WHEREAS, Plaintiffs served the Complaint on Defendant on January 5, 2017;

WHEREAS, Defendant filed a Motion to Dismiss the Complaint on February 24, 2017;

WHEREAS, Plaintiffs filed an Amended Complaint on April 7, 2017, containing significant amendments;

WHEREAS, Defendant's response to Plaintiffs' Amended Complaint is currently due on May 12, 2017;

WHEREAS, the Parties are engaged in discussions to determine whether it is feasible to resolve this matter without the need for further litigation;

WHEREAS, the Parties agree that a brief two-week continuance of the deadline for Defendant to respond to Plaintiffs' Amended Complaint will facilitate the Parties' settlement discussions, and result in a more efficient expenditure of judicial resources;

WHEREAS, the Parties request that Defendant's deadline to respond to Plaintiffs' Amended Complaint, currently set for May 12, 2017, be continued to May 26, 2017;

WHEREAS, the Parties have previously requested one extension of time for Defendant to file a response to Plaintiffs' Amended Complaint;

WHEREAS, counsel for Defendant, as the filer of this document, attests that concurrence in the filing of the document has been obtained from each of the other signatories;

IT IS THEREFORE STIPULATED BETWEEN THE PARTIES THAT, subject to the Court's approval:

1. Defendant's response to Plaintiffs' Amended Complaint shall be continued from May 12, 2017, until May 26, 2017.

General Order 45, Section X Certification

The filing attorney hereby certifies that concurrence in the filing of the document has been obtained from each signatory, in accordance with N.D. Cal. Gen. Order 45, Section X(B).

[PROPOSED] ORDER

Having reviewed the Parties' Joint Stipulation and [Proposed] Order Concerning Time to File Response to Amended Complaint, and for good cause appearing, IT IS HEREBY ORDERED THAT:

1. Defendant's response to Plaintiffs' Amended Complaint shall be continued from May 12, 2017, until May 26, 2017.

IT IS SO ORDERED.