STIPULATION AND [PROPOSED] ORDER TO STAY CASE

EDWARD J. DAVILA, District Judge.

STIPULATION

In furtherance of judicial economy and to avoid potentially unnecessary expense, the undersigned counsel for and on behalf of the parties named below wish to stay all proceedings in this action pending a final outcome in Plaintiffs Writ of Administrative Mandamus ("Writ"), filed in Santa Cruz County Superior Court, Case No. CISCV 173577.

Accordingly, Plaintiff FRANCISCO IBARRA ("Plaintiff') and Defendants CITY OF WATSONVILLE, CARLOS PALACIOS, MANNY SOLANO, TERENCE MEDINA, and BELCHER, EHLE, MEDINA AND ASSOCIATES ("Defendants") by and through their respective counsels (collectively referred to as "the parties") hereby STIPULATE and AGREE as follows:

WHEREAS Plaintiff filed a petition in Santa Cruz County Superior Court to obtain a Writ of Administrative Mandamus on March 16, 2012;

WHEREAS Plaintiff filed this action ("Civil Action") in United States District Court for the Northern District of California on May 4, 2012;

WHEREAS many of the same underlying facts and legal issues are presented in the Writ and the Civil Action;

WHEREAS Defendants filed a Motion to Dismiss the Civil Action on November 13, 2012 and the Court granted Defendants' Motion on February 15, 2013, allowing Plaintiff 30 days leave to amend;

WHEREAS a hearing on the Writ is set for March 27, 2013;

WHEREAS the parties acknowledge that the earliest date a decision can become final in the Writ is when the sixty day window to appeal any Superior Court decision on the Writ has expired, pursuant to Cal. Rules of Ct. 8.104;

WHEREAS the parties wish to stay all proceedings in this matter at the present time, including hearings, briefings, appearance, and any other deadlines imposed by law or the Court, pending a final decision being entered in the related Writ, which is economically and judicially efficient;

WHEREAS the parties further stipulate and agree that the extension requested herein is not requested for the purposes of delay and will not result in any prejudice to the parties or to the Court;

IT IS THEREFORE STIPULATED AND AGREED by Plaintiff and Defendants, by and through their respective counsel, and the Court is respectfully requested to order that:

IT IS SO STIPULATED.

[PROPOSED] ORDER

Pursuant to the foregoing stipulation, and good cause appearing, I hereby Order that:

CISCV 173577. or until April 30, 2013, whichever date occurs first, Counsel for Defendant City shall notify the court when a final decision on the Writ has been entered. This stay may be extended on the request of the parties should the circumstances so warrant;

The court schedules this case for a Case Management Conference on June 7, 2013, at 10:00 a.m. The parties shall file a Joint Case Management Statement on or before May 31, 2013.