STIPULATION AND ORDER ESTABLISHING BRIEFING SCHEDULE FOR PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT

JOHN A. MENDEZ, District Judge.

Pursuant to Local Rule 230, all parties to this case hereby stipulate and request that the Court approve the following briefing schedule for Plaintiffs' motion for summary judgment, filed on September 7, 2016, and set for hearing on November 15, 2016, at 1:30 p.m.:

Plaintiffs' motion was filed on September 7, 2016.

Defendants' oppositions to the motion and any cross-motions for summary judgment must be served and filed on or before October 11, 2016.

Plaintiffs' replies to Defendants' oppositions and Plaintiffs' opposition to any cross-motions must be served and filed on or before November 1, 2016.

Defendants' replies in support of any cross-motion must be served and filed on or before November 8, 2016.

The Parties stipulate and agree that they met and conferred regarding Plaintiffs' motion on August 25, 2016. The Parties further stipulate and agree that, during the proposed briefing schedule, they will not propound additional discovery.

As provided for in Local Rule 230(e), notwithstanding this stipulation, should Defendants file any cross-motions for summary judgment, Plaintiffs reserve their rights to request that the Court modify the briefing schedule and "continue the hearing on the original and all related motions so as to give all parties reasonable opportunity to serve and file oppositions and replies to all pending motions." Plaintiffs will meet and confer with Defendants prior to making such a request.

Good cause exists for this briefing schedule because counsel for Defendant State Building and Construction Trades Council of California, AFL-CIO, will be out of the country for several weeks in early September. And counsel for Defendants Harris, Baker, Ravnik, and Rodriguez will be out of the office on family leave for several weeks in early October. Moreover, providing extra time for the parties to incorporate cross-motions into the schedule will reduce the burden on the Court and the parties.

Accordingly, the parties request that the Court approve the briefing schedule.

IT IS SO STIPULATED.

ORDER

Good cause appearing, it is hereby ORDERED that for Plaintiffs' motion for summary judgment scheduled to be heard on November 15, 2016, at 1:30 p.m.:

Defendants' oppositions to the motion and any cross-motions for summary judgment must be served and filed on or before October 11, 2016.

Plaintiffs' replies to Defendants' oppositions and Plaintiffs' opposition to any cross-motions must be served and filed on or before November 1, 2016.

Defendants' replies in support of any cross-motion must be served and filed on or before November 8, 2016.

As provided for in Local Rule 230(e), notwithstanding this stipulation, should Defendants file any cross-motions for summary judgment, Plaintiffs reserve their rights to request that the Court modify the briefing schedule and "continue the hearing on the original and all related motions so as to give all parties reasonable opportunity to serve and file oppositions and replies to all pending motions." Plaintiffs will meet and confer with Defendants prior to making such a request.

IF DEFENDANTS' FILE A CROSS-MOTION FOR SUMMARY JUDGMENT THE COURT MAY VERY LIKELY CONTINUE THE NOVEMBER 15, 2016 HEARING DATE. OTHERWISE THE STIPULATION IS APPROVED.

IT IS SO ORDERED.