STIPULATION OF PARTIES TO CONTINUE HEARING AND TO EXTEND ASSOCIATED DEADLINES; ORDER

(Fed. R. Civ. P. 6(b)(1)(A); Local Rules 144, 230(f))

JOHN A. MENDEZ, District Judge.

I. INTRODUCTION

The parties, Plaintiff California Rifle and Pistol Association and Defendants Bureau of Alcohol, Tobacco, Firearms, and Explosives, Attorney General Eric Holder, and ATF Director B. Todd Jones, through their respective attorneys of record, hereby jointly stipulate to continue the date of the hearing for Defendants' Motion to Dismiss, or Alternatively, for Summary Judgment and to extend the remaining deadlines for filing moving papers related to that motion in accordance with the stipulated schedule set forth below.

This request is made pursuant to Rule 6 of the Federal Rules of Civil Procedure and Rules 144 and 230 of the Local Rules of the Eastern District of California.

II. RECITALS/GROUNDS FOR RELIEF

WHEREAS, Plaintiffs filed their initial Complaint in this matter on July 31, 2014;

WHEREAS, Defendants filed their Motion to Dismiss, or Alternatively, for Summary Judgment on January 9, 2015;

WHEREAS, Defendants noticed their Motion to Dismiss, or Alternatively, for Summary Judgment for March 25, 2015 at 9:30 a.m. in the courtroom of the Honorable John A. Mendez;

WHEREAS, pursuant to Local Rule 230(c), Plaintiff must file its Opposition to Defendants' Motion to Dismiss, or Alternatively, for Summary Judgment on or before March 11, 2015;

WHEREAS, Local Rule 144(a) of this Court allows a 28-day extension of time for responding to complaints and filing certain other documents by initial stipulation of the parties without approval of the court, but states that "[a]ll other extensions of time must be approved by the Court";

WHEREAS, Rule 6(b)(1)(A) of the Federal Rules of Civil Procedure allows for the extension of time for good cause, "if a request is made, before the original time or its extension expires";

WHEREAS, good cause for an extension of time is shown in that Plaintiff is currently considering voluntary dismissal of this matter and has expressed such to Defendants;

WHEREAS, the continuance and extension requested herein will conserve both the Court's and all parties' time and resources and promote judicial economy by attempting to avoid the preparation and consideration of unnecessary briefing and argument on Defendants' Motion to Dismiss, or Alternatively, for Summary Judgment;

WHEREAS, both parties to this action seek to keep the costs of litigation as low as reasonably possible;

WHEREAS, this request for continuance and extension is made in good faith, and it is not for the purpose of unnecessary delay; and

WHEREAS, neither party has obtained an extension of time relating to any matter for which this extension is sought.

THE PARTIES STIPULATE AND AGREE TO THE FOLLOWING:

Alternatively, for Summary Judgment shall be continued to May 6, 2015 at 9:30 a.m.;

2. Plaintiffs' Opposition to Defendants' Motion to Dismiss, or Alternatively, for Summary Judgment shall be due on or before April 10, 2015; and

3. Defendants' Reply in support of their motion shall be due on or before April 29, 2015.

The parties hereby jointly request that this Court grant the relief sought by this stipulation.

PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS SO ORDERED.