JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE MANAGEMENT CONFERENCE AND EXTEND DEFENDANT'S TIME TO RESPOND TO PLAINTIFFS' AMENDED COMPLAINT

EDWARD M. CHEN, District Judge.

Plaintiffs and Defendant FORD MOTOR COMPANY ("Ford") (collectively the "Parties"), by and through their respective counsel, hereby stipulate as follows:

WHEREAS, Plaintiff David Baranco filed a putative class action complaint in the Northern District of California, San Francisco Division, on June 21, 2017 (the "Original Complaint");

WHEREAS, upon stipulation of the parties, Ford's time to respond to the Original Complaint was extended to August 25, 2017;

WHEREAS, on July 10, 2017, the Court entered a Case Management Order setting a case management conference for September 21, 2017;

WHEREAS, on August 18, 2017, before any response to the Original Complaint was filed, Plaintiffs filed a First Amended Class Action Complaint ("Amended Complaint"), which added ten additional plaintiffs from 7 additional states;

WHEREAS, Ford's response to the Amended Complaint is currently due on September 1, 2017;

WHEREAS, due to a trial in another matter for Ford's counsel and the additional number of Plaintiffs and claims asserted in the Amended Complaint, Ford has requested and Plaintiffs have agreed to extend Ford's time to respond to the Amended Complaint until October 16, 2017;

WHEREAS, the parties agree that adjourning the case management conference to a date after Ford responds to the Amended Complaint is appropriate to preserve judicial economy and the parties resources and to make the conference more efficient and useful; and

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:

1. The last day for Ford to file a response to Plaintiffs' Amended Complaint in the above-entitled action shall be October 16, 2017; and

2. The Case Management Conference set for September 21, 2017 shall be adjourned and reset to a new date after October 16, 2017, which shall be determined

[PROPOSED] ORDER

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

1. Defendant Ford Motor Company's response to Plaintiffs' Amended Complaint in the above-entitled action shall be continued from September 1, 2017 to October 16, 2017; and

2. The Case Management Conference set for September 21, 2017 is adjourned and reset to November 21, 2017 at 10:00 a.m. in Courtroom 5.

IT IS SO ORDERED.