STIPULATION EXTENDING PAGE LIMIT FOR DEFENDANTS' JOINT REPLY IN SUPPORT OF MOTION TO DISMISS PLAINTIFF'S COMPLAINT; PROPOSED ORDER

JON S. TIGAR, District Judge.

Plaintiff California Restaurant Association ("CRA") and Defendants City of Emeryville ("Emeryville") and Unite Here Local 2850 ("Local 2850) (collectively, "the Parties") hereby stipulate and agree that: 1) Emeryville and Local 2850 may file a Joint Reply in Support of Motion to Dismiss Plaintiff's Complaint in excess of the fifteen (15) page limitation set forth in Civil Local Rule 7-4(b), but not to exceed thirty (30) pages in length; and 2) CRA may file a Supplemental Reply by March 3, 2017 to address the Exhibits to the Declaration of Mr. Huber, which were inadvertently omitted from the Huber Declaration when initially filed and served, and are reflected in Emeryville's Notice of Errata to Declaration of Wei-Ling Huber in Support of City of Emeryville's Opposition to Motion for Preliminary Injunction (Document No. 28-1). This Stipulation is made pursuant to Rules 7-3, 7-11, 7-12 of the United States District Court for the Northern District California.

There is good cause for the Stipulation to extend the page limit on the grounds that this case involves several numerous complex and novel legal issues. Emeryville and Local 2850 are filing a Joint Reply, and require more than fifteen (15) pages to sufficiently address all the arguments raised. As background, Emeryville's points and authorities in support of its Motion to Dismiss total twenty-five (25) pages. Local 2850 also filed a brief totaling twenty-four (24) pages in support of the Motion to Dismiss. Plaintiff's Opposition to Emeryville's Motion to Dismiss totals thirty-five (35) pages. The extended page limit will also serve the interests of judicial economy and efficiency because there is overlap between the arguments advanced by both Emeryville and Local 2850. Thus, filing one Joint Reply, rather than two separate briefs, will decrease paperwork and will ultimately serve to narrow the issues in this case.

Because Emeryville and Local 2850 require more than 15 pages to sufficiently address all arguments raised by CRA, the Parties therefore agree that Emeryville and Local 2850 may be permitted 30 pages to respond to CRA's Opposition to the Motion to Dismiss. The Parties also agree that good cause exists for CRA to file a Supplemental Reply to address the Exhibits to the Declaration of Mr. Huber, which are reflected in Emeryville's Notice of Errata to Declaration of Wei-Ling Huber in Support of City of Emeryville's Opposition to Motion for Preliminary Injunction. Good cause exists because the exhibits were inadvertently excluded from the initial filing and service, and CRA did not receive the exhibits until the afternoon of February 28, 2017—the day its Reply in Support of Motion for Preliminary Injunction was due.

IT IS SO STIPULATED.

PROPOSED ORDER

Defendants' Motion for Extra Pages pursuant to the Parties' Stipulation is granted. Emeryville and Local 2850 may file a Joint Reply up to 30 pages in support of motion to dismiss. CRA may file a 10-page supplemental reply in support of its Motion for Preliminary Injunction. This supplemental reply is due by March 3, 2017.