STIPULATION AND ORDER EXTENDING TIME FOR DEFENDANTS CALIFORNIA STATEWIDE LAW ENFORCEMENT ASSOCIATION AND CALIFORNIA ASSOCIATION OF LAW ENFORCEMENT EMPLOYEES TO FILE RESPONSIVE PLEADING

JOHN A. MENDEZ, District Judge.

Plaintiff TERRY C. COOLEY ("Plaintiff"), and Defendants CALIFORNIA STATEWIDE LAW ENFORCEMENT ASSOCIATION, CALIFORNIA ASSOCIATION OF LAW ENFORCEMENT EMPLOYEES, XAVIER BECERRA, ERIC BANKS, PRISCILLA WINSLOW, ERICH SHINERS, and ARTHUR A. KRANTZ (together, the "Defendants"; Plaintiffs and Defendants together are the "Parties") by and through their counsel, and pursuant to Local Rule 144(a), hereby stipulate as follows:

WHEREAS on November 30, 2018, Defendants California Statewide Law Enforcement Association and California Association of Law Enforcement Employees (the "Union Defendants") filed a stipulation with the Court to extend the time to file a responsive pleading to the Complaint by 28 days—to January 3, 2019 (ECF No. 15).

WHEREAS the Union Defendants filed a Motion to Dismiss the Complaint on January 3, 2019 (ECF No. 22).

WHEREAS the Court dismissed the Union Defendants' Motion to Dismiss the Complaint on January 29, 2019 for failure to include a meet and confer statement in the Notice of Motion to Dismiss the Complaint (ECF Nos. 22-1, 43).

WHEREAS the Union Defendants' counsel met and conferred with Plaintiff's counsel about the Union Defendants' Motion to Dismiss on January 30, 2019. It was established at that meet and confer that, by amending the Complaint, the number of issues in any future motion to dismiss could be reduced. Plaintiff's counsel therefore indicated that it intended to soon file an amended complaint.

WHEREAS because it was not economic or efficient to respond to a complaint that would be amended, the Parties stipulated to an extension for the Union Defendants to file a responsive pleading to the Complaint to February 22, 2019, which the Court granted (ECF No. 45).

WHEREAS the Parties have been working to resolve issues raised in the Union Defendants' Motion to Dismiss the Complaint to minimize the disputed issues for the Court to resolve.

WHEREAS Plaintiff intends to file the First Amended Complaint on February 22, 2019.

WHEREAS on February 8, 2019, the Court granted the state defendants' stipulation for an extension of time to file a responsive pleading until 45 days after Plaintiff files and serves an amended complaint (ECF No. 48).

WHEREAS in order to streamline all Defendants' motions to dismiss such that they are heard at approximately the same time, and because it is not economic or efficient to respond to a complaint that will soon be amended, the Parties agree the time for the Union Defendants to file a responsive pleading will be 45 days after the filing and service of an amended complaint, which will be the same date that the state defendants will file a responsive pleading to the amended complaint.

STIPULATION

NOW THEREFORE, the Parties agree that the time for the Union Defendants to file and serve a response to the operative complaint is extended to 45 days after Plaintiff files and serves an amended complaint.

IT IS SO STIPULATED.

ORDER

GOOD CAUSE APPEARING, it is hereby ORDERED that:

The deadline for Defendants California Statewide Law Enforcement Association and California Association of Law Enforcement Employees to file and serve a response to the operative complaint is extended to 45 days after Plaintiff files and serves an amended complaint.

IT IS SO ORDERED.