JOINT STIPULATION REQUESTING EXTENSION OF TIME FOR DEFENDANTS' RESPONSE TO PLAINTIFF'S AMENDED COMPLAINT AND MODIFYING BRIEFING SCHEDULE

WILLIAM ALSUP, District Judge.

Subject to the Court's approval, the Parties stipulate as follows:

WHEREAS, on November 24, 2014, Plaintiff filed a Complaint for Declaratory and Injunctive Relief. ECF No. 1.

WHEREAS, on December 1, 2014, this Court issued a Related Case Order, finding that this lawsuit is related to City of Berkeley v. United States Postal Service ("City of Berkeley"), C 14-04916 WHA (filed Nov. 5, 2014). See ECF No. 15. Defendants' responsive pleading in City of Berkeley is currently due January 22, 2015, and this Court has scheduled a case management conference on the matter for March 19, 2015, at 8:00 AM (Order dated December 29, 2014).

WHEREAS, on December 31, 2014, Plaintiff in the present lawsuit filed an Amended Complaint for Declaratory and Injunctive Relief. ECF No. 21.

WHEREAS, Defendants' responsive pleading is currently due January 23, 2015, and the case management hearing scheduled for February 19, 2015.

WHEREAS, undersigned counsel for Defendants requests an additional six days to file a response to Plaintiff's amended complaint, up to and including January 29, 2015.

WHEREAS, an additional six days will allow the Defendants to prepare a comprehensive and well-organized responsive pleading. It will also ensure that Defendants have adequate time to complete the internal review process within the Department of Justice and the United States Postal Service for both this case and City of Berkeley.

WHEREAS, the Parties also agree to a stipulation that provides one additional week beyond the time allowed in Civil L.R. 7.3 for Plaintiff's response and Defendants' reply: Plaintiff's response to Defendants' responsive pleading would be due February 19, and Defendants' reply due March 5.

WHEREAS, the requested extension for both parties takes into account the complex nature of the briefing involved (see Commentary to Civil L.R. 7-2, 7-3).

WHEREAS, the Parties also request that this Court continue the case management conference in this case (scheduled for February 19, 2015) to March 19, 2015, to coincide with the case management conference to be held in City of Berkeley. Because of the overlap between the two related cases, combining the two case management conferences will save the resources of both this Court and the Parties. Plaintiff's counsel in this matter have conferred with Plaintiffs' counsel in the City of Berkeley case who have stated that they have no objection to this proposed schedule.

WHEREAS, the requested extension will not unduly delay the proceedings in this matter.

NOW, THEREFORE, pursuant to Civil L.R. 6-2, and subject to the Court's approval, the Parties hereby stipulate that the time for Defendants to respond to the Amended Complaint in this matter shall be extended until and including January 29, 2015. The Parties also stipulate that Plaintiff's response to Defendants' responsive pleading is due February 19, and Defendants' reply due March 5. The Parties also stipulate, subject to this Court's approval, that the case management conference in this case, scheduled for February 19, 2015, be continued to March 19, 2015, to coincide with the case management conference in City of Berkeley.

PROPOSED ORDER

Pursuant to stipulation, IT IS SO ORDERED. Defendants shall have until January 29, 2015, to respond to Plaintiff's amended complaint. Plaintiff's response to Defendants' responsive pleading is due February 19, and Defendants' reply is due March 5. The hearing on any motion to dismiss filed by Defendants, as well as the case management conference, are hereby continued to March 19, 2015, at 8:00 a.m.