JOINT STIPULATION PER LOCAL RULE 6-2 and [PROPOSED] ORDER REGARDING MOTION AND CASE MANAGEMENT SCHEDULE

RICHARD SEEBORG, District Judge.

STIPULATION

Plaintiffs Joan Ambrosio et al. ("Plaintiffs") and Defendant Cogent Communications, Inc. ("Defendant")(collectively, the "Parties"), through their counsel, hereby stipulate and agree that:

WHEREAS, on July 14, 2014, Defendant filed its Motion for Judgment on the Pleadings to be heard in this Court on August 14, 2014 (Dkt. 12-14);

WHEREAS, on July 15, 2014, the Court continued the hearing on the Motion to August 28, 2014 at 1:30 p.m. (Dkt. 15);

WHEREAS, Plaintiffs' counsel has several upcoming deadlines that conflict with the current briefing schedule and hearing date, including a motion for class certification and a hearing on that motion in a proposed statewide employment class action, an appeal in an individual employment case, and active discovery including rescheduled depositions in an individual discrimination case;

WHEREAS, the Parties have not previously sought any extension of time in this action;

WHEREAS, the Parties also propose that the Court continue the Initial Case Management Conference, currently set for August 21, 2014, to the same date as the hearing on Defendant's motion.

NOW, THEREFORE, Plaintiffs and Defendant, through their respective counsel, hereby stipulate, subject to the approval of the Court, to the following schedule:

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.