STIPULATION REQUESTING CONTINUANCE OF JUNE 19, 2014 CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES

EDWARD M. CHEN, District Judge.

TO THE COURT, TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD:

This Stipulation is submitted pursuant to Local Rule 6-2 and is entered into by and between all Plaintiffs and Defendants represented by the undersigned counsel (collectively, "Stipulating Defendants," and collectively, with Plaintiffs, the "Parties") for the purpose of efficiently managing this litigation involving numerous parties and complex issues.

A. The original Complaint in this matter was filed on October 27, 2013.

B. On November 1, 2013, the Court issued its Case Management Conference Order in Reassigned Cases (Dkt. No. 10) scheduling the initial Case Management Conference ("CMC") on January 30, 2014 at 9:00 a.m. and directing that the Parties file a Joint CMC Statement one week in advance.

C. Pursuant to the parties' stipulation and Court's subsequent order thereon, filed January 6, 2014 (the "January 6, 2014 Stipulation and Order") (Dkt. No. 27), Plaintiffs filed a First Amended Complaint ("FAC") on January 27, 2014 (Dkt. No. 29). The January 6, 2014 Stipulation and Order included a briefing schedule for any Rule 12 motions and set the hearing for any such motions, as well as the date for a continued CMC, on April 10, 2014.

D. On March 10, 2014, pursuant to stipulation, the Court entered an Order Regarding Case Management Conference (the "March 10, 2014 Order") (Dkt. No. 54) directing the Defendants to file their responsive pleadings by April 24, 2014, directing Plaintiffs to file their oppositions to any motions to dismiss by May 22, 2014, directing Defendants to file their replies by June 5, 2014, and scheduling the hearing of any motions directed at the FAC along with the CMC for June 19, 2014 at 1:30 p.m.

E. In adherence with the deadlines set forth in the March 10, 2014 Order, Stipulating Defendants filed their respective Rule 12 motions directed to the FAC (Dkt. Nos. 99; 106; 107; 109/110; and 114/115/136), and Plaintiffs filed their respective oppositions on May 22, 2014 (Dkt Nos. 145; 146; 147; 149; and 150).

F. Pursuant to the March 10, 2014 Order, Stipulating Defendants' replies are due by June 5, 2014, the Parties' Joint CMC Statement is due by June 12, 2014, and parties are required to confer regarding the matters set forth in the Order Setting Initial Case Management Conference and ADR Deadlines (Dkt. No. 4) by May 29, 2014, and to file ADR-related documents.

G. The Parties wish to be able to confer as efficiently and reasonably as possible regarding Rule 26(f) and ADR-related matters, and respectfully believe it is premature to do so given the presently uncertain status of the pleadings until after the Court's upcoming rulings, which will likely affect the Parties' Rule 26(f) and ADR-related discussions and analysis.

H. Accordingly, the Parties now respectfully seek the Court's approval of a continuance of the CMC presently set for June 19, 2014, along with all attendant CMC-related deadlines, until after the Court's ruling on the motions to dismiss.

I. This Stipulation is not offered for any dilatory or improper purpose, but rather solely to effectively manage the scheduling of case events and to ensure the most efficient use of resources by the Court, the Parties, and their counsel.

WHEREFORE, subject to the Court's approval, Plaintiffs and the Stipulating Defendants, desiring to efficiently manage this complex matter, hereby stipulate to a continuance of the CMC and related deadlines until a date approximately six weeks after the Court's issuance of its rulings on the pending Rule 12 motions.

ORDER

Pursuant to the Stipulation of counsel and for good cause shown, IT IS HEREBY ORDERED that the Case Management Conference is continued to 7/24/14 at 9:30 a.m.

A joint CMC Statement shall be filed by 7/17/14.

IT IS SO ORDERED.