1 Stephanie Sheridan (CA 135910) Meegan B. Brooks (CA 298570) 2 Benesch, Friedlander, Coplan & Aronoff LLP 100 Pine Street, Suite 3100 3 San Francisco, California 94111 Telephone: 628.600.2250 4 Facsimile: 628.221.5828 Email: [email protected] 5 [email protected]

6 Attorneys for Defendant 7 LOWE’S HOME CENTERS, LLC 8

9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 PRESCILA LOVELL, for herself, as a Case No. 2:25-cv-03453-TLN-SCR 13 private attorney general, and on behalf of all others similarly situated, 14 STIPULATION AND ORDER TO EXTEND Plaintiff, TIME FOR DEFENDANT LOWE’S HOME 15 CENTERS, LLC TO RESPOND TO v. PLAINTIFF’S COMPLAINT 16 LOWE’S HOME CENTERS, LLC,

17 Defendant. 18

19 20 21 22 23 24 25 26 27 1 Pursuant to Federal Rule of Civil Procedure 16(b)(4) and Local Rule 144(a), Plaintiff Prescila 2 Lovell (“Plaintiff”) and Defendant Lowe’s Home Centers, LLC (“Defendant”) (collectively, the 3 “Parties”), by and through their respective counsel, hereby stipulate that Defendant’s deadline to respond 4 to the Complaint in the above-captioned action is extended a total of fifty-one (51) days from December 5 3, 2025 to and including January 23, 2026. A court may modify a deadline for good cause. Fed. R. Civ.

(b). Indeed, modifying or extending a responsive deadline is within the discretion of the trial judge. 7 See Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992). 8 Good cause exists for extending Defendant’s deadline to respond to the Complaint. Defendant 9 just removed this action on November 26, 2025, and needs further time to assess the allegations, especially 10 given the intervening holidays. The Parties have not previously requested any extensions of time to 11 respond. The Parties therefore request that the Court extend Defendant’s deadline to respond to the 12 Complaint to January 23, 2026, and stipulate and request that the Court approve the following schedule: 13 Defendant’s deadline to file a Motion to Dismiss January 23, 2026 14 Plaintiff’s deadline to file an Opposition February 20, 2026 15 Defendant’s deadline to file a Reply March 6, 2026 16 17 IT IS SO STIPULATED. 18 Dated: December 3, 2025 Respectfully submitted,

19

20 s/ Stephanie Sheridan STEPHANIE SHERIDAN (CA 135910) 21 MEEGAN B. BROOKS (CA 298570) Benesch, Friedlander, Coplan & Aronoff LLP 22 100 Pine Street, Suite 3100 San Francisco, California 94111 23 [email protected] [email protected] 24 Attorneys for Defendant 25 LOWE’S HOME CENTERS, LLC

26

27 Dated: December 3, 2025 Respectfully submitted, s/ Daniel Hattis (with authorization) 2 Daniel Hattis (CA 232141) 3 Paul Karl Lukacs (CA 197007) Hattis, Lukacs & Corrington 4 11711 SE 8th Street, Suite 120 Bellevue, WA 98005 5 [email protected] ‘ [email protected] 7 Attorneys for PRESCILA LOVELL, for herself, as a private attorney general, and on behalf of all g others similarly situated 9 ORDER 10 IT IS SO ORDERED 7, 11 12 Dated this 5" day of December, 2025 Troy L. Nunley 13 Chief United States District Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28