STIPULATION TO EXTEND DEADLINE TO SUBMIT PROPOSED ORDER REGARDING JOINT LETTER BRIEF ON DISCOVERY FILED DECEMBER 23, 2015

JON S. TIGAR, District Judge.

Plaintiffs James Lathrop, Julie McKinney, Jonathan Grindell, Sandeep Pal, Jennifer Reilly, and Justin Bartolet (collectively, "Plaintiffs") and Defendant Uber Technologies, Inc. ("Defendant"), by and through their respective attorneys of record, stipulate and agree as follows:

WHEREAS, Plaintiffs James Lathrop, Julie McKinney, Jonathan Grindell, Sandeep Pal, Jennifer Reilly, and Justin Bartolet ("Plaintiffs") and Defendant Uber Technologies, Inc. ("Defendant" or "Uber") submitted a joint letter outlining the parties' current discovery disputes (Docket No. 100);

WHEREAS, the Court heard argument from the parties on January 7, 2016 on the issues in the joint letter and ordered the Plaintiffs to submit a Proposed Order regarding the scheduling of a Rule 30(b)(6) deposition of Uber;

WHEREAS, following the hearing on January 7, 2016, the Parties have been engaged in further meet and confer discussions regarding the scheduling of, and topics to be included in, the Rule 30(b)(6) depositions of Uber, including (but not limited to) the Rule 30(b)(6) deposition of Uber related to discovery issues, as well as other scheduling issues;

WHEREAS, the Parties agree that a brief amount of additional time is necessary to finalize the discussions for the Proposed Order;

WHEREAS, the Parties request a one-day extension of the deadline to submit the Proposed Order.

IT IS HEREBY STIPULATED THAT:

The Parties agree, subject to Court approval, to submit a Proposed Order consistent with the Court's direction at the January 7, 2016 hearing on January 13, 2016.

Pursuant to Local Civil Rule 6-2(a), attached as Exhibit A is a joint declaration in support of this Stipulation.

PURSUANT TO STIPULATION, IT IS SO ORDERED.