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Dee Hensley-Maclean and Jennifer Rosen, On Behalf of v. Safeway

May 22, 2012

DEE HENSLEY-MACLEAN AND JENNIFER ROSEN, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
SAFEWAY INC. AND DOES ONE THROUGH TWENTY, INCLUSIVE,
DEFENDANTS.



OBINSON

CLASS ACTION STIPULATION RE REVISED JOINT PROPOSED SCHEDULE FOR CLASS CERTIFICATION Judge: Hon. Richard Seeborg Dept.: 3 - 17th floor

Pursuant to Civil Local Rule 6-2, the parties respectfully submit this Stipulation re Revised Joint Proposed Briefing Schedule for Class Certification in this action which modifies the Court's 25 previous Order re Joint Briefing Schedule for Class Certification (Doc. 57). As set forth in the 26 accompanying Declaration of Jesse F. Ruiz, the parties held a full day of mediation before Martin 27

Quinn, Esq. of JAMS on April 24, 2012. The parties continue to work with Mr. Quinn in hope of 28 resolving this litigation. The mutually-agreeable revised briefing schedule set forth in this Stipulation will provide the parties the time to continue and complete the mediation process in 2 good faith without the complication and imposition of immediate scheduling obligations in this 3 action.

1. Class Certification. Plaintiffs' class certification motion pursuant to Federal Rule 5 of Civil Procedure 23 shall be filed with an opening brief on or before August 13, 2012. 6

Defendant's opposition brief shall be filed no later than 45 days after filing of the motion. 7

Plaintiffs' reply brief shall be filed no later than 45 days after filing of the opposition brief. After 8 the Court rules on class certification, the parties will submit proposed dates for merits discovery, 9 dispositive motions, and trial. 10

2. Hearing on Class Certification. Hearing on the class certification motion will be experts retained relating to class certification are due from the plaintiffs by August 13, 2012, and from defendant by September 27, 2012. Reports from rebuttal experts retained relating to class 15 certification are due by November 19, 2012. The parties will serve all discovery requests relating to class certification so as to be completed by October 31, 2012, however, for good cause shown, a party may conduct class discovery solely relating to rebuttal expert reports after October 31, 2012.

Dated: May 22, 2012 19

Respectfully submitted, 20

Center for Science in the Public Interest Robinson & Wood, Inc. 21

/s/ Stephen Gardner /s/ Gabriel G. Gregg 22

Stephen Gardner Jesse F. Ruiz 23

Seema Rattan Gabriel G. Gregg 5646 Milton Street, Suite 211 227 N. 1st Street 24

Dallas, TX 85206 San Jose, CA 95113 Telephone: (214) 827-2774 ...


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