STIPULATION AND [PROPOSED] ORDER REGARDING HEARING SCHEDULE FOR CASE MANAGEMENT CONFERENCE, MOTION TO COMPEL ARBITRATION, AND PLAINTIFFS' MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT

EDWARD M. CHEN, District Judge.

STIPULATION

Plaintiffs Douglas O'Connor, Thomas Colopy, Matthew Manahan, and Elie Gurfinkel ("Plaintiffs") and Defendant Uber Technologies, Inc. ("Uber") (collectively, the "Parties"), by and through their respective counsel of record, hereby stipulate as follows:

WHEREAS, the Court has scheduled a case management conference in this case for October 21, 2015 at 9:30 a.m.;

WHEREAS, on September 10, 2015, Uber filed a motion to compel arbitration as to certain absent class members in this case, see Dkt. No. 346;

WHEREAS, the hearing for Uber's motion to compel arbitration as to certain absent class members is currently scheduled for October 21, 2015 at 9:30 a.m.;

WHEREAS, on October 1, 2015, Plaintiffs filed a motion for leave to file a fourth amended complaint in this case, see Dkt. 355;

WHEREAS, the hearing for Plaintiffs' motion for leave to file a fourth amended complaint is currently scheduled for November 19, 2015 at 1:30 p.m.;

WHEREAS, counsel for Plaintiffs represents the named plaintiffs in Yucesoy v. Uber Technologies, Inc., No. 15-cv-00262-EMC ("Yucesoy") and counsel for Uber represents the defendants in Yucesoy;

WHEREAS, on August 5, 2015, the Yucesoy defendants filed a motion to compel arbitration as to certain of the named plaintiffs in Yucesoy, see Yucesoy Dkt. No. 94;

WHEREAS, the hearing for the Yucesoy defendants' motion to compel arbitration is currently scheduled for October 21, 2015 at 9:30 a.m.;

WHEREAS, on August 28, 2015, the Yucesoy defendants filed a motion to dismiss the Yucesoy plaintiffs' second amended complaint, see Yucesoy Dkt. No. 109;

WHEREAS, the hearing for the Yucesoy defendants' motion to dismiss the Yucesoy plaintiffs' second amended complaint is currently scheduled for October 21, 2015 at 9:30 a.m.;

WHEREAS, the Court has scheduled a case management conference in Yucesoy for November 19, 2015 at 10:30 a.m.;

WHEREAS, certain unavoidable scheduling conflicts have arisen for certain of the parties' counsel on October 21, 2015 and November 19, 2015;

WHEREAS, certain of the parties' counsel will be traveling to San Francisco from Los Angeles and Boston for the aforementioned hearings;

WHEREAS, the Court is unavailable on the following Civil Law and Motion hearing dates: October 22, 2015; November 5, 2015; November 12, 2015; and November 26, 2015;

WHEREAS, the Yucesoy parties intend to file a stipulation and proposed order requesting that the Yucesoy parties' case management conference, the Yucesoy defendants' motion to compel arbitration as to certain named plaintiffs, and the Yucesoy defendants' motion to dismiss the second amended complaint be scheduled for November 4, 2015 at 1:30 p.m.;

WHEREAS, to accommodate the aforementioned scheduling conflicts and conserve the resources of the Court and the parties, the parties have conferred and agreed that: (1) the case management conference; (2) the hearing for Uber's motion to compel arbitration as to certain unnamed class members; and (3) the hearing for Plaintiffs' motion for leave to file a fourth amended complaint should be rescheduled for November 4, 2015 at 1:30 p.m., to coincide with the proposed hearing date regarding the case management conference in Yucesoy, the defendants' motion to dismiss in Yucesoy, and the defendants' motion to compel arbitration as to certain of the named plaintiffs in Yucesoy;

NOW THEREFORE, the parties hereby stipulate, subject to the approval of this Court, that the hearing date for (1) the case management conference, (2) Uber's motion to compel arbitration as to certain absent class members, and (3) Plaintiffs' motion for leave to file a fourth amended complaint shall be scheduled for November 4, 2015 at 1:30 p.m. 10:00 am; and (4) the parties' case management statement shall be due October 28, 2015.

IT IS SO STIPULATED

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

The hearing date is set for November 4, 2015 at 10:00 a.m.