STIPULATION TO CONTINUE FILING OF MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT, OPPOSITION THERETO; AND [PROPOSED] ORDER

EDWARD M. CHEN, District Judge

Pursuant to Local Rules 6-1, 6-2, and 7-12, Plaintiffs Tasion Communications Inc., International Power Systems, LLC, and Fundamental Holdings, Corp. (collectively, "Plaintiffs") and Defendants Ubiquiti Networks, Inc. ("Ubiquiti") and Streakwave Wireless, Inc. ("Streakwave") (Ubiquiti and Streakwave collectively, the "Defendants;" and Plaintiffs and Defendants collectively, the "Parties"), by and through their undersigned counsel, submit this Stipulation to Continue Filing of Motion for Leave to File an Amended Complaint and the Opposition Thereto.

WHEREAS, the deadline for Plaintiffs' to file a motion for leave to file an amended complaint is February 12, 2105, and Defendants' deadline to file their Opposition Thereto is February 19, 2015, as presently ordered (Dkt. No. 119), and said dates are based on Ubiquiti's completion of its document production on or before February 5, 2015;

WHEREAS, Ubiquiti is experiencing delays in getting the documents processed by and ready for review from its third party E-Discovery vendor;

WHEREAS, as a result, Ubiquiti is experiencing delays in getting the final production ready to serve from the third party E-Discovery vendor;

WHEREAS, Local Rule 6-1 permits the Parties to stipulate in writing without a court order, "to enlarge or shorten the time in matters not required to be filed or lodged with the Court, provided the change will not alter the date of any event or any deadline already fixed by Court order" Local Rule 6-1(a);

WHEREAS, the Parties are not aware of any date fixed by Court order that will be altered by the Parties' stipulated request, absent the Court's execution of this [proposed] Order (which would modify the dates of the briefing and hearing on the Motion for Leave to File an Amend Complaint);

WHEREAS, the requested extension will not otherwise alter the schedule of this case, including the briefing and hearing schedule for class certification; and

WHEREAS, this Stipulation is made in good faith and not for the purposes of delay.

NOW THEREFORE, IT IS HEREBY STIPULATTED AND AGREED, by and between the Parties, through their undersigned counsel of record, that the last day for Ubiquiti to complete its production of document in response to Plaintiffs' request for production of document shall be February 20, 2015; the deadline for Plaintiffs' filing of an Amended Complaint or Motion for Leave to File an Amended Complaint shall be February 27, 2015, and Defendants' Opposition Thereto shall be filed by March 3, 2015, with the Motion hearing (if needed) on March 12, 2015 at 1:30 p.m. or such other time and date convenience for the Court.

ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3)

I, N. Kathleen Strickland, am the ECF user whose identification and password are being used to file the foregoing Stipulation to Continue Filing of Motion for Leave to File an Amended Complaint; Opposition Thereto; and [proposed] Order. I hereby attest that the above-referenced signatories to this Stipulation to Continue Filing of Motion for Leave to File an Amended Complaint; Opposition Thereto; and [proposed] Order have concurred in this filing.

PURSUANT TO STIPULATION, IT IS SO ORDERED

The Court, having reviewed the Stipulation of the Parties and finding good cause, hereby issues an Order as follows:

1. The deadline for Ubiquiti to complete its final document production shall be continued from February 5, 2015, to February 20, 2015;

2. The deadline for Plaintiffs to file an Amended Complaint or Motion for Leave to File an Amended Complaint shall be continued from February 12, 2015, to February 27, 2015;

3. The deadline for Defendants file an Opposition Thereto shall be continued from February 19, 2015, to March 3, 2015; and

4. The hearing on Plaintiffs' Motion for Leave to File an Amended Complaint (if needed) shall be continued from March 3, 2015, to March 26, 2015, at 1:30 p.m. or such other time and date convenient for the Court.

IT IS SO ORDERED.