STIPULATED REQUEST TO CONTINUE UPCOMING DEADLINES; PROPOSED ORDER

WILLIAM B. SHUBB, Senior District Judge.

STIPULATION

WHEREAS, Plaintiffs filed their First Amended Complaint (ECF No. 20) on November 2, 2018;

WHEREAS, Defendants Governor Edmund G. Brown, Jr., Attorney General Xavier Becerra, State Controller Betty Yee, California Department of Corrections and Rehabilitation Acting Secretary Ralph Diaz, and the Public Employment Relations Board ("State Defendants") filed a Motion to Dismiss the Complaint (ECF No. 51) on November 30, 2018;

WHEREAS, Defendants AFSCME Local 2620 and AFSCME Local 3299 ("Union Defendants") filed a Motion for Partial Judgment on the Pleadings (ECF No. 56) on January 3, 2019;

WHEREAS, the hearing for both the Motion to Dismiss and Motion for Partial Judgment on the Pleadings ("Dispositive Motions") is scheduled for February 4, 2019, at 1:30 p.m., in Courtroom 5;

WHEREAS, Plaintiffs filed a Response to the Motion to Dismiss and Motion for Partial Judgment on the Pleadings ("Response;" ECF No. 59) on January 21, 2019;

WHEREAS, in the Response, Plaintiffs stated their intention to file a Motion for Leave to Amend the Complaint;

WHEREAS, in subsequent discussions between counsel, counsel for Plaintiffs stated that they intend on filing a Motion for Leave to Amend the Complaint within the next three (3) weeks;

WHEREAS, the State and Union Defendants' Reply Briefs for their Dispositive Motions are currently due on January 28, 2019;

WHEREAS, a Motion for Leave to Amend the Complaint, if granted, would render moot the State Defendants' Motion to Dismiss and the Union Defendants' Motion for Judgment on the Pleadings;

WHEREAS, a continuance of the deadlines for the reply briefs and the hearing on the Dispositive Motions, if necessary, conserves the resources of the parties and this Court;

WHEREAS, in its Order Re: Status (Pretrial Scheduling) Conference (ECF No. 5), issued on September 4, 2018, the Court scheduled the Pretrial Scheduling Conference for February 25, 2019, at 1:30 p.m., and ordered the parties: (1) to confer as required under Rule 26(f) of the Federal Rules of Civil Procedure (FRCP) at least twenty-one (21) calendar days before the hearing; and (2) to file a Joint Status Report at least fourteen (14) calendar days before the hearing.

WHEREAS, the resolution of any Motion for Leave to Amend the Complaint may greatly affect the scope, nature, and amount of discovery required for this matter;

WHEREAS, continuing the deadlines for initial disclosures and completion of Joint Status Report until after resolution of the Motion for Leave to Amend the Complaint will conserve the parties' and the Court's resources, as it could eliminate the need for completion of unnecessary discovery and disclosures;

WHEREAS, continuing the deadlines for the Dispositive Motions, the Pretrial Scheduling Conference, the meet-and-confer requirement, and the Joint Status Report will not interfere with any pending Court deadlines or prejudice any of the parties in this matter; and

WHEREAS, the parties have not previously requested any extensions of time for the Dispositive Motions, completion of the meet and confer requirements, Joint Status Report, or the Pretrial Scheduling Conference;

THEREFORE, the parties hereby stipulate, by and through their counsel of record, as follows:

IT IS SO STIPULATED.

ORDER

Pursuant to the above stipulation between the parties, and for good cause shown, the Court extends the following deadlines:

IT IS SO ORDERED.