STIPULATION REQUESTING CONTINUANCE OF AUGUST 14, 2014 CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES

EDWARD M. CHEN, District Judge.

TO ALL PARTIES AND THEIR ATTORNEYS 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.

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

2. 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.

3. Pursuant to the parties' stipulation and the 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.

4. On March 10, 2014, pursuant to stipulation, the Court entered an Order Regarding Case Management Conference (the "March 10, 2014 Order") (Dkt. No. 54). In accordance with the deadlines set forth in the March 10, 2014 Order, Stipulating Defendants filed their respective Rule 12 motions directed to the FAC ("Rule 12 Motions") (Dkt. Nos. 99; 106; 107; 109/110; and 114/115/136), Plaintiffs filed their respective oppositions on May 22, 2014 (Dkt Nos. 145; 146; 147; 149; and 150), and Defendants filed their Replies on June 5, 2014 (Dkt Nos. 155-159).

5. On May 29, 2014, pursuant to stipulation, the Court ordered a continuance of the Case Management Conference from June 19, 2014, to July 24, 2014 and the Case Management Statement of the Parties was ordered due by July 17, 2014 (Dkt No. 154).

6. The hearing on the Rule 12 Motions was held on July 10, 2014 before the Court, after which the Court took the Rule 12 Motions under submission (Dkt. No. 171). Pursuant to the Clerk's Notice dated July 11, 2014, the Case Management Conference scheduled for July 24, 2014, was continued to August 14, 2014, and the Case Management Statement of the Parties was ordered due by August 7, 2014.

7. Pursuant to the July 11, 2014 Clerk's Notice, the 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 July 24, 2014, and to file ADR-related documents. 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 uncertain status of the pleadings until after the Court's rulings on the Rule 12 Motions, which will likely affect the Parties' Rule 26(f) and ADR-related discussions and analysis.

8. Accordingly, the Parties now respectfully ask the Court to continue the CMC presently set for August 14, 2014, along with all attendant CMC-related deadlines, until forty-five (45) days after the Court's ruling on the motions to dismiss.

9. 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 at least forty-five (45) days after the Court's issuance of its rulings on the Rule 12 Motions currently under submission which is convenient for the Court's calendar.

ORDER

Pursuant to the Stipulation of counsel and for good cause shown, IT IS HEREBY ORDERED that the case management conference is continued to 9/18/14 at 10:30 a.m.. An updated joint CMC Statement shall be filed by 9/11/14.

IT IS SO ORDERED.