STIPULATION AND [PROPOSED] ORDER REGARDING HEARING SCHEDULE FOR DEFENDANTS' MOTION TO COMPEL ARBITRATION, AND DEFENDANTS' MOTION TO DISMISS

EDWARD M. CHEN, District Judge.

STIPULATION

Plaintiffs Hakan Yucesoy, Abdi Mahammed, Mohktar Talha, Brian Morris, and Pedro Sanchez ("Plaintiffs") and Defendants Uber Technologies, Inc., Travis Kalanick, and Ryan Graves ("Uber") (collectively, the "Defendants"), by and through their respective counsel of record, hereby stipulate as follows:

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

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

WHEREAS, on August 28, 2015, Defendants filed a motion to dismiss Plaintiffs' second amended complaint, see Dkt. No. 109;

WHEREAS, the hearing for Defendants' motion to dismiss 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 for November 19, 2015 at 10:30 a.m.;

WHEREAS, counsel for Plaintiffs represents the named plaintiffs in O'Connor v. Uber Technologies, Inc., No. 13-03826-EMC ("O'Connor") and counsel for Defendants represents the defendant in O'Connor;

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

WHEREAS, on September 10, 2015, the O'Connor defendant filed a motion to compel arbitration as to certain absent class members in O'Connor, see O'Connor Dkt. No. 346;

WHEREAS, the hearing for the O'Connor defendant'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, the O'Connor plaintiffs filed a motion for leave to file a fourth amended complaint in O'Connor, see O'Connor Dkt. 355;

WHEREAS, the hearing for the O'Connor plaintiffs' motion for leave to file a fourth amended complaint is currently scheduled for November 19, 2015 at 1:30 p.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 O'Connor parties intend to file a stipulation and proposed order requesting that the O'Connor parties' case management conference, the O'Connor defendant's motion to compel arbitration as to certain unnamed class members, and the O'Connor plaintiffs' motion for leave to file a fourth 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 hearing for Defendants' motion to compel arbitration as certain named plaintiffs in this case; (2) the hearing for Defendants' motion to dismiss Plaintiffs' second amended complaint; and (3) the case management conference in this case 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 O'Connor, the defendants' motion to compel arbitratoin in O'Connor, and the plaintiffs' motion for leave to file a fourth amended complaint in O'Connor;

NOW THEREFORE, the parties hereby stipulate, subject to the approval of this Court, that the hearing date for (1) Defendants' motion to compel arbitration as certain named plaintiffs, (2) Defendants' motion to dismiss Plaintiffs' second amended complaint, and (3) the case management conference shall be scheduled for November 4, 2015 at 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.