JOINT STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER
The parties to the above-referenced action stipulate as follows: WHEREAS, on March 3, 2011, the Court issued its Status (Pretrial Scheduling) Order (Docket No. 16) setting the following pretrial deadlines:
1. Pre-certification discovery cut-off: August 15, 2011;
2. Plaintiff's Motion for Class Certification: December 16, 2011;
3. Defendant's Opposition: December 30, 2011;
4. Plaintiff's Reply: January 6, 2012; and
5. Hearing on Class Certification: January 13, 2012.
WHEREAS, the parties are engaging in discovery;
WHEREAS, the parties have not yet finalized a stipulated protective order, in part, because Defendant must ensure that any such order complies with its obligations to third parties;
WHEREAS, the parties intend to continue working toward completing discovery and agree that additional time is necessary to prepare for class certification;
WHEREAS, the parties have met and conferred to determine a schedule for briefing and hearing the Plaintiff's Motion for Class Certification that accommodates previously scheduled travel and unavailability of counsel;
THE PARTIES THEREFORE STIPULATE AND REQUEST THAT the Court vacate the above-referenced deadlines, and set new deadlines as follows:
1. Pre-certification discovery cut-off: December 16, 2011;
2. Plaintiff's Motion for Class Certification: ...