STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

EDWARD M. CHEN, District Judge.

Defendant Maplebear, Inc., d/b/a Instacart ("Instacart") and Plaintiffs Dominic Cobarruviaz, Arlin Golden, John Reilly, Christopher Russell, Susan Bannon, Batya Weber, and Derek Williams (together, "Plaintiffs") hereby stipulate and respectfully request that the Court continue the Case Management Conference in this matter, currently scheduled for January 12, 2017 at 10:30 a.m., until March 2, 2017 at 9:30 a.m.

Good cause exists for this requested continuance:

WHEREAS, on December 1, 2016, Plaintiffs' counsel filed a new case in this Court styled Husting et al. v. Maplebear, Inc. d/b/a Instacart, No. 16-cv-6921; and

WHEREAS, on December 7, 2016, the parties in this matter stipulated that this case and the Husting case are related pursuant to Civil Local Rule 3-12 of the Northern District of California, see Dkt. 140; and

WHEREAS, on December 7, 2016, this Court issued an order relating this case and the Husting case, see Dkt. 142; and

WHEREAS, the initial case management conference in the Husting case is scheduled for March 2, 2017 at 9:30 a.m. The parties agree that it would be most efficient for the Court to hold a single case management conference on March 2, 2017 for both the Husting case and this matter.

THEREFORE, the parties hereby stipulate as follows:

STIPULATION

1. Pursuant to Civil Local Rule 6-2 of the Northern District of California, the parties, by and through their undersigned counsel, hereby stipulate and respectfully request a continuance of the Case Management Conference until March 2, 2017 at 9:30 a.m. so that the conference can be conducted in conjunction with the initial case management conference in the Husting case and to avoid the inefficiency for the Court and the parties in holding two separate case management conferences. Pursuant to Civil Local Rule 6-2(a), Instacart is contemporaneously filing the Declaration of Benjamin Berkowitz in support of this stipulation and proposed order.

2. The requested time modification would have no effect on other deadlines in this case.

3. All parties agree to this stipulation. In accordance with Civil Local Rule 5-1(i), Defendant Instacart's undersigned counsel, Benjamin Berkowitz, hereby attests that Julie Erickson, counsel for Plaintiffs, concurs in the filing of this Stipulation and Proposed Order.

4. The parties respectfully request that the Court approve the stipulation, pursuant to Civil Local Rule 6-2 and enter an Order thereupon. A form of Proposed Order is filed herewith.

[PROPOSED] ORDER

The Court having considered the above joint request, and good cause appearing therefore, HEREBY ORDERS that the scheduled Case Management Conference date of January 12, 2017 is vacated, and shall be rescheduled for hearing on March 2, 2017 at 9:30 a.m.

IT IS SO ORDERED.