STIPULATION AND [PROPOSED] ORDER

INDIRA TALWANI, District Judge.

WHEREAS, Plaintiffs Marian Ryan, Rachael Rollins, Committee for Public Counsel Services, and the Chelsea Collaborative, Inc. (collectively, "Plaintiffs") filed the complaint in this action on April 29, 2019 (the "Complaint") (see Dkt. No. 1);

WHEREAS Defendants U.S. Immigration and Customs Enforcement, Matthew T. Albence, Todd M. Lyons, U.S. Department of Homeland Security, and Kevin McAleenan (collectively, "Defendants") plan to move to dismiss the Complaint;

WHEREAS Defendants' motion to dismiss was originally due on June 28, 2019 (see Dkt. No. 54);

WHEREAS Defendants sought and obtained, with Plaintiffs' consent, a 60-day extension of time, until August 27, 2019, to move to dismiss the Complaint (see Dkt Nos. 53, 54);

WHEREAS Defendants sought and obtained, with Plaintiffs' consent, an additional 60-day extension of time, until October 29, 2019, to move to dismiss the Complaint (see Dkt. Nos. 58, 60);

WHEREAS Defendants now seek an additional extension of time to move to dismiss the complaint; Plaintiffs seek an extension of time to oppose Defendants' motion to dismiss; and Defendants seek to file a reply in support of their motion to dismiss;

WHEREAS Defendants take the position that Plaintiffs are not entitled to any discovery and that, even if Plaintiffs are entitled to discovery, such discovery should not begin until after this Court rules on Defendants' motion to dismiss, while Plaintiffs take the position that they are entitled to discovery and that such discovery should begin while this Court considers Defendants' motion to dismiss;

NOW, THEREFORE, Plaintiffs and Defendants, by and through their undersigned counsel, jointly stipulate and agree as follows:

1. Defendants shall file their motion to dismiss the Complaint on or before December 13, 2019.

2. Plaintiffs shall file their opposition to Defendants' motion to dismiss on or before January 31, 2019.

3. Defendants shall file any reply brief in support of their motion to dismiss on or before February 28, 2019.

4. The parties are prepared to attend a Scheduling Conference pursuant to Local Rule 16.1(a) at the earliest date that is practicable for the Court, although request the opportunity to present their respective positions as to the propriety and timing of discovery at this stage of proceedings as part of any such process before any discovery commences.

SO ORDERED.