STIPULATION AND ORDER TO FILE AMENDED ANSWERS TO COMPLAINT AND FIRST AMENDED CROSS-COMPLAINT

JOHN A. MENDEZ, District Judge.

The parties, by and through their respective counsel, hereby agree and jointly stipulate pursuant to Federal Rule of Civil Procedure 15(a) to allow Plaintiff and Counter-defendant California State Employees Association ("CSEA") to file an Amended Answer to Defendant and Counterclaimant Richard Bogart's ("Counterclaimant") First Amended Cross-Complaint and to allow Counterclaimant to file an Amended Answer to CSEA's Complaint, as follows:

RECITALS

A. WHEREAS, Counterclaimant filed his Answer to CSEA's Complaint on or about October 22, 2014 and CSEA filed its Answer to Defendant and Counter-Plaintiff Richard Bogart's First Amended Cross-Complaint on or about March 16, 2015; and

B. WHEREAS, both parties now seek to file Amended Answers to the operative Complaint and Cross-Complaint ("Amended Answer"), copies of which are attached hereto as Exhibits A and B, respectively; and

C. WHEREAS, both parties have agreed to the other's request for a stipulation to file the attached Amended Answers; and

D. WHEREAS, by stipulating to the filing of the Amended Answers, neither party waives its right to challenge the new affirmative defenses in the Amended Answers by any permissible means.

STIPULATION

NOW THEREFORE, in light of the foregoing recitals, IT IS HEREBY STIPULATED by and between CSEA and Counterclaimant, by and through their respective counsel, that CSEA and Counterclaimant may file the Amended Answers attached hereto as Exhibits A and B. DOWNEY BRAND LLP

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.