CLASS ACTION

STIPULATION AND ORDER TO EXTEND DEFENDANT'S RESPONSIVE PLEADING DEADLINE AND RELATED DEADLINES

HAYWOOD S. GILLIAM, Jr., District Judge.

Plaintiff Irving Firemen's Relief & Retirement Fund ("Plaintiff") and Defendant Travis Kalanick ("Kalanick"), by and through their undersigned counsel, hereby stipulate as follows:

WHEREAS, on September 26, 2017, Plaintiff filed its Complaint against Kalanick and Uber Technologies, Inc. ("Uber");

WHEREAS, the undersigned counsel for Kalanick is authorized to accept service of the Summons and Complaint on behalf of Kalanick;

WHEREAS, Plaintiff served Kalanick with the Summons and Complaint on October 24, 2017 by delivering a copy of each to counsel for Kalanick via e-mail and U.S. Mail;

WHEREAS, the Honorable Donna M. Ryu to whom this case was initially assigned entered an order governing Uber's time to answer or otherwise respond to the Complaint on October 16, 2017 (Dkt. No. 12);

WHEREAS, the case was reassigned to the Honorable Haywood S. Gilliam, Jr. on October 20, 2017, but the briefing schedule for motions did not change (Dkt. No. 15);

WHEREAS, to the extent Kalanick moves to dismiss the Complaint, the parties have agreed that the motion will be briefed on the same schedule previously entered by Judge Ryu with respect to any motion to dismiss filed by Uber;

WHEREAS, the parties' proposed extension of Kalanick's responsive pleading deadline will not change or alter the date of any event or any deadline already fixed by Court order;

WHEREAS, Plaintiff has selected Robbins Geller Rudman & Dowd LLP ("Robbins Geller") to serve as Lead Counsel for the putative class in this litigation and Kalanick has no objection to Plaintiff's selection of Lead Counsel;

IT IS HEREBY STIPULATED AND AGREED, by and between the parties, through their undersigned counsel and subject to this Court's approval:

1. Kalanick's deadline to answer or otherwise respond to Plaintiff's Complaint is extended through and including December 1, 2017.

2. If Kalanick moves to dismiss, Plaintiff may respond by January 17, 2018, and Kalanick may reply by February 14, 2018.

IT IS SO STIPULATED.

CERTIFICATE PURSUANT TO LOCAL RULE 5-1(I)(3)

I, DARRYL J. ALVARADO, am the ECF User whose identification and password are being used to file the STIPULATION AND [PROPOSED] ORDER TO EXTEND DEFENDANT'S RESPONSIVE PLEADING DEADLINE AND RELATED DEADLINES. In compliance with Local Rule 5-1(i)(3), I hereby attest that JAMES N. KRAMER has concurred in this filing.

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ORDER

Pursuant to stipulation, IT IS SO ORDERED.