STIPULATION AND [PROPOSED] ORDER RE PLAINTIFFS' RENEWED EMERGENCY MOTION FOR PROTECTIVE ORDER TO STRIKE ARBITRATION CLAUSES AND DEFENDANTS' MOTION TO DISMISS PLAINTIFFS' CLASS ACTION COMPLAINT

EDWARD M. CHEN, District Judge.

STIPULATION

Plaintiffs DOUGLAS O'CONNOR and THOMAS COLOPY ("Plaintiffs") and Defendants UBER TECHNOLOGIES, INC., TRAVIS KALANICK, and RYAN GRAVES ("Defendants") (collectively, the "Parties"), through their counsel, hereby stipulate and agree that:

WHEREAS, Plaintiffs filed Plaintiffs' Renewed Emergency Motion for Protective Order to Strike Arbitration Clauses [Dkt. No. 15] with the Court on August 26, 2013;

WHEREAS, the Court issued a Notice [Dkt. No. 38] on September 18, 2013, which set the hearing date for Plaintiffs' Renewed Emergency Motion for Protective Order to Strike Arbitration Clauses as October 17, 2013 at 1:30pm;

WHEREAS, Defendants filed Defendants' Motion to Dismiss Plaintiffs' Class Action Complaint [Dkt. No. 39] with the Court on September 25, 2013;

WHEREAS, the hearing date for Defendants' Motion to Dismiss Plaintiffs' Class Action Complaint [Dkt. No. 39] was set as October 31, 2013 at 01:30pm;

WHEREAS, the Parties have conferred and agreed to consolidate the hearing dates for Plaintiffs' Renewed Emergency Motion (October 17, 2013) and Defendants' Motion to Dismiss (October 31, 2013) and to schedule them both for November 7, 2013, at 01:30pm, pending approval of this Court;

WHEREAS, the Court set the response date for Defendants' Motion to Dismiss as October 9, 2013, and the reply date as October 16, 2013;

WHEREAS, the Parties have conferred and agreed to revise the response date for Defendants' Motion to Dismiss as October 17, 2013, and the reply date as October 24, 2013;

WHEREAS, the Court issued a Case Management Scheduling Order [Dkt. No. 24] on September 3, 2013, which set the initial scheduling conference date as November 21, 2013;

WHEREAS, the Parties have conferred and agreed to postpone the initial scheduling conference set for November 21, 2013 until after the Court rules on the two motions referenced above;

NOW, THEREFORE, Plaintiffs and Defendants, through their respective counsel, hereby stipulate, subject to the approval of this Court, that the hearing dates for Plaintiffs' Renewed Emergency Motion for Protective Order to Strike Arbitration Clauses and Defendants' Motion to Dismiss Plaintiffs' Class Action Complaint be consolidated and rescheduled for November 7, 2013 at 01:30pm, and to extend the time allotted for Plaintiffs to respond to Defendants' Motion to Dismiss Complaint, and Defendants to reply to Plaintiffs' response, to October 17, 2013 and October 24, 2013, respectively.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.