WILLIAM B. SHUBB, District Judge.
Plaintiffs Ravinder Rangi and Melissa C. Macias ("Plaintiffs") and Defendant ExamSoft Worldwide, Inc. ("Defendant"), hereby jointly submit this Stipulation regarding Defendant's time to respond to the Complaint.
WHEREAS, on August 15, 2014, Plaintiffs filed the Complaint in this action and served Defendant on August 26, 2014;
WHEREAS, several other plaintiffs have filed similar complaints against Defendant in various other jurisdictions;
WHEREAS, to ensure that this litigation and the other, similar actions pending against Defendant progress in an orderly and efficient manner; NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED as follows:
2. If Defendant moves to dismiss the Complaint, Plaintiffs' opposition shall be due on or before December 12, 2014, and Defendant's reply shall be due January 12, 2015.
3. If Defendant agrees to, or is ordered to comply with, an earlier response date to any other complaint involving the same or similar claims as those alleged in this Complaint, then its response date to this Complaint will be such earlier date.
4. By submitting this Stipulation, Defendant does not waive and expressly reserves any available defenses, including lack of personal jurisdiction and improper service of process.