STIPULATION AND [PROPOSED] ORDER TO MODIFY BRIEFING SCHEDULE AND HEARING DATE ON PLAINTIFFS' MOTION TO DISSOLVE DISCOVERY STAY RE: COUNTS 9, 12, & 15 AS MODIFIED HEREIN

JEFFREY S. WHITE, District Judge.

Pursuant to Fed. R. Civ. P. 6(b)(1) & Civil L.R. 6-2, the Government Defendants request, and the parties, through their undersigned counsel, hereby stipulate to and respectfully request the Court (1) to extend by one week the deadline for the Government Defendants' response to Plaintiffs' Motion To Dissolve the Discovery Stay Re: Counts 9, 12, & 15 (Dkt. No. 334), and (2) to re-schedule the hearing on Plaintiffs' motion from February 5 to February 12, 2016.

Plaintiffs filed their motion to lift the discovery stay on January 1, 2016, and noticed a hearing on their motion for February 5, 2016. Pursuant to Civil L.R. 7-3(a), the Government Defendants' response to Plaintiffs' motion is currently due to be filed on January 15, 2016. The Government Defendants seek an extension of that deadline due to multiple pre-existing filing deadlines in other matters, all occurring during the first two weeks of January. The press of business in these other matters has made it impracticable for counsel to prepare the Government Defendants' response to Plaintiffs' motion by January 15. The Government Defendants therefore seek a one-week extension of that deadline to January 22, 2016.1

The Government Defendants also seek an equivalent one-week postponement of the hearing on Plaintiffs' motion, due to the unavailability on February 5 of their lead counsel, James Gilligan. Mr. Gilligan's son, who recently enlisted in the United States Marine Corps, will return home from boot camp for a short leave beginning January 29, 2016, and must report again for duty on February 8. Mr. Gilligan does not wish to be away for a two-day trip to the west coast during his son's brief stay.

There have been no prior requests to alter the briefing or hearing schedule on Plaintiffs' motion to lift the discovery stay. The changes requested herein should not impact the overall schedule of this case.

DECLARATION PURSUANT TO CIVIL L.R. 5-1 AND 6-2

I, James J. Gilligan, hereby declare (1) pursuant to Civil L.R. 5-1, that I have obtained Plaintiffs' concurrence in the filing of this document from Richard R. Wiebe, counsel for Plaintiffs, and (2) pursuant to Civil L.R. 6-2, that the reasons given above for the enlargements of time requested herein are true and correct.

* * * *

The Court grants the stipulation, as modified herein:

PURSUANT TO STIPULATION, it is ORDERED that (1) the deadline to file the Government Defendants' response to Plaintiffs' Motion To Dissolve the Discovery Stay Re: The reply is due on January 29, 2016 Counts 9, 12, & 15 (Dkt. No. 334) is extended from January 15 to January 22, 2016, and (2) the hearing on Plaintiffs' motion is rescheduled from February 5 to February 12, 2016. February 26, 2016.

IT IS SO ORDERED.