STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND CERTAIN DEADLINES IN CURRENT CASE MANAGEMENT ORDER

[N.D. Cal. LR 6-1]

EDWARD J. DAVILA, District Judge.

STIPULATED REQUEST

Pursuant to Civil Local Rule 6-2, Plaintiffs Donna J. Forsyth, Sidney L. Staton III, Arun Vatturi, Dan Weiland, Karen Becks, Ed Kaplan, Albert Devere, and Shafiq Rahman (hereafter collectively "Plaintiffs") and Defendants HP Inc. and Hewlett Packard Enterprise Company (hereafter collectively "Defendants") (Plaintiffs and Defendants are hereafter referred to as the "Parties"), hereby jointly submit a stipulated request for an order of the Court extending certain deadlines contained in the Court's June 19, 2017 Case Management Order. This stipulated request is supported by the accompanying Declaration of Richard W. Black.

In support of this stipulation, the Parties agree and stipulate as follows:

1. Plaintiffs initiated the present action against Defendants in the United States District Court for the Northern District of California on August 18, 2016. (See ECF, Doc. No. 1.)

2. Defendants were served with the Summons and original Complaint in this action on August 23, 2016.

3. By stipulation, the Parties agreed to a sixty (60) day extension of time for Defendants to respond to the original Complaint. (See ECF, Doc. No. 14.). Pursuant to the stipulation, Defendants' responded to the original Complaint on November 14, 2016. (See ECF, Doc. Nos. 42-44.)

4. On December 19, 2016, Plaintiffs filed an Amended Complaint. (See ECF, Doc. No. 60.). Defendants' responded to the Amended Complaint on January 30, 2017. (See ECF, Doc. Nos. 74-75.)

5. On June 15, 2017, the Parties submitted a Joint Case Management Statement. (See ECF, Doc. No. 121). On June 19, 2017, the Court issued the current Case Management Order in the case addressing deadlines prior to the filing of Plaintiffs' Motion for Conditional Certification and the briefing and hearing date on that motion. (See ECF, Doc. No. 122) ("Current Case Management Order").

6. In the Court's June 19, 2017, the Court established the following schedule:

7. Both prior to and following the entry of the Current Case Management Order, the parties have engaged in discovery on both sides, and have worked to address and attempt to resolve discovery issues. Despite these efforts, the Parties believe that it is necessary to extend certain of the dates contained in the Current Case Management Order so that the Parties can attempt to complete pre-conditional certification expert disclosures, discovery, and expert discovery prior to the filing of Plaintiffs' Motion for Conditional Certification.

8. The Parties thus, by this stipulated request, respectfully request that the Court enter an order extending each date in the Current Case Management Order (with the exception of the date for the Hearing on Plaintiffs' Motion for Conditional Certification) to the dates in the chart below:

9. This Stipulation will not alter the date of the hearing on Plaintiffs' Motion for Conditional Certification, which would still be set for May 17, 2018.

10. This is the first extension of the dates set forth in the Current Case Management Order in this matter.

IT IS SO STIPULATED.