STIPULATION AND ORDER ENLARGING PLAINTIFFS' TIME TO RESPOND TO DEFENDANTS' MOTION TO DISMISS

[Civ. L.R. 6-2]

HAYWOOD S. GILLIAM, Jr., District Judge.

Plaintiffs Peter Schuman and William Coplin (collectively "Plaintiffs") and Defendants Microchip Technology, Inc., Atmel Corporation, and Atmel Corporation U.S. Severance Guarantee Benefit Program (collectively "Defendants"), herein referred to collectively as the "Parties," hereby stipulate, by and through their respective attorneys of record, as follows:

WHEREAS, Defendants filed a Rule 12(b)(6) motion to dismiss Plaintiffs' Amended Complaint on April 28, 2017 (Dkt. 33);

WHEREAS, on April 28, 2017, Defendants also filed a motion to dismiss the complaint in the related case Berman, et al. v. Microchip Technology, Inc., et al., Case No. 5:17-CV-01864-HSG (N.D. Cal.), in which the plaintiffs are represented by the same counsel representing Plaintiffs in this matter;

WHEREAS, pursuant to Civil Local Rule 7-3(a), Plaintiffs' oppositions to Defendants' motions to dismiss in both cases are currently due May 12, 2017;

WHEREAS, Defendants agree to extend the deadline for Plaintiffs to respond to both motions to dismiss to and including May 31, 2017; and

WHEREAS, the stipulated extension of time for Plaintiffs to respond to Defendants' motions to dismiss will not affect any other dates or deadlines in this case;

THEREFORE, THE PARTIES HEREBY STIPULATE that Plaintiffs' time to respond to Defendants' motion to dismiss (Dkt. 33) is extended up to and including May 31, 2017. The hearing on the motion will remain set for June 22, 2017 at 2:00 p.m., or as soon thereafter as this Court is available.

PURSUANT TO STIPULATION, IT IS SO ORDEERED.

DECLARATION OF MICHAEL RUBIN IN SUPPORT OF STIPULATION

I, Michael Rubin, declare as follows:

1. I am a member in good standing of thee bar of the State of California and am one of the counsel of record for Plaintiffs Peter Schuman and William Coplin (collectively "Plaintiffs") in the above-captioned case. I am also one of the counsel of record for Plaintiffs Robin Berman, Bo Kang, Khashayar Mirfakhraei, Thang Van Vu, Donna Viera-Casstillo, Girish Ramesh, Patrick Hanley, Ilana Shternshain and Mandy Schwarz in the related case Berman, et al. v. Microchip Technology, Inc., et al., Case No. 5:17-CV-01864-HSG (N.D. Cal.). I make this declaration in support of the Parties' stipulated request to enlarge the time for Plaintiffs to respond to Defendants' motion to dismiss. The facts set forth in this declaration I know tto be true of my own personal knowledge, except where stated to be based on information and belief.

2. The procedural history of this case, including prior time modifications, is set out in the Court's December 22, 2016 Order on the Parties' Joint Stipulation to Withdraw Defendants' Motion to Dismiss and for Plaintiffs to File Amended Complaint. Dkt. 27. Pursuant to that Stipulation and Order, Plaintiffs filed an Amended Complaint on March 31, 2017. Dkt. 229.

3. On April 28, 2017, Defendants filed a motion to dismiss Plaintiffs' complaint in this action. Dkt. 33. That same day, Defendants also filed a motion to dismiss the complaint in Berman.

4. Pursuant to Civil Local Rule 7-3(a), Plaintiffs' oppositions to Defendants' motions to dismiss in both cases are currently due May 12, 2017. Due to preeexisting work obligations, Plaintiffs' counsel are unable to file both oppositions by May 12, 2017.

5. I conferred with counsel for Defendants, and Defendants agree to extend the deadline for Plaintiffs to respond to both motions to dismiss to and includiing May 31, 2017.

6. To the best of my knowledge, the requested time modification will have no effect on the schedule for the case.

I declare under penalty of perjury that the foreegoing is true and correct to the best of my knowledge. Executed at San Francisco, California, on May 8, 2017.