STIPULATION TO CONTINUE HEARING DATE ON, AND SET BRIEFING SCHEDULE FOR, PLAINTIFFS' MOTION FOR CLASS CERTIFICATION; [PROPOSED] ORDER THEREON

WILLIAM B. SHUBB, District Judge.

TO THE COURT:

The parties to the above-captioned case hereby submit the following stipulation to continue the hearing date on Plaintiffs' previously-noticed motion for class certification from January 26, 2015, to April 20, 2015, and to set a briefing schedule for the filing and service of the opposition and reply briefs thereon.

WHEREAS, on August 15, 2014, Plaintiffs noticed their motion for class certification to be heard on September 22, 2014;

WHEREAS, the parties to the above-captioned case had previously agreed that, after Plaintiffs noticed that motion, the hearing on the motion would be stayed to permit Defendants to conduct discovery relevant to the class certification issue, and so informed the Court in their Revised Joint Status Report, Doc. No. 20 at 3:15-18;

WHEREAS, the parties thereafter stipulated to continue the hearing on the motion to January 26, 2015, with a corresponding briefing schedule;

WHEREAS, the Court approved that stipulation on September 5, 2014 (Docket No. 24);

WHEREAS, it is taking Plaintiffs longer than the parties had previously contemplated to respond to the written discovery requests propounded by Defendant SEIU Local 1000, which has given them several extensions of time within which to respond;

WHEREAS, Defendant SEIU Local 1000 is still awaiting some of the Plaintiffs' responses to those written discovery requests, and must receive them before it can determine which Plaintiffs it will need to depose;

WHEREAS, the parties contemplate scheduling the necessary depositions in January and early February, followed by time to brief the issues relevant to class certification; and

WHEREAS, the parties continue to wish to implement their prior agreement and to set a briefing schedule for the opposition and reply on the class certification motion so that Plaintiffs will have sufficient time to prepare their reply;

THEREFORE, the parties hereby stipulate as follows:

1. The hearing on Plaintiffs' pending motion for class certification shall be continued from January 26, 2015, to April 20, 2015, at 2:00 p.m.

2. This stipulation shall constitute sufficient notice of that continuance, so that Plaintiffs need not file an amended notice of motion.

3. Any oppositions to Plaintiffs' class certification motion that Defendants submit shall be filed and served on or before March 27, 2015.

4. Any reply in support of Plaintiffs' class certification motion shall be filed and served, as per the Local Rules, on or before April 10, 2015.

The foregoing is so stipulated and agreed between the parties to the above-captioned action, by among their undersigned counsel.

ORDER

IT IS SO ORDERED.