JOINT CASE MANAGEMENT CONFERENCE STATEMENT AND PROPOSED ORDER TO CONTINUE CMC HEARING AND ORDER THEREON

MAXINE M. CHESNEY, Senior District Judge.

The Parties to the above-entitled action jointly submit this Joint Case Management Statement and Proposed Order pursuant to the Standing Order for All Judges of the Northern District of California, Civil Local Rule 16-9, and in accordance with this Court's Orders of August 15, 2014 (document #45) and October 29, 2014 (document #59). Based on the parties' ongoing discovery efforts, the parties propose continuing the January 16, 2015 Case Management Conference hearing until March 6, 2015.

Brief status update and good cause for request for continuance:

Motions

Defendant United States of America timely filed its motion to dismiss pursuant to FRCP 12(b)(1) on October 31, 2014. On October 22, 2014, the Court approved a request for extended page limits and also continued the hearing date on the motion until March 27, 2015. After ongoing efforts to meet and confer, the parties disagreed on the need for further extensions of the briefing schedule and hearing date. On December 16, 2014, the DNC defendants submitted a motion to extend the time for jurisdictional discovery and extend the briefing schedule (document #77). The court referred this dispute to Magistrate Judge Kandis A. Westmore (document #78). Pursuant to Judge Westmore's standing order, the parties jointly submitted a letter detailing the dispute and the parties' positions (document #79).

Judge Westmore issued a new dispositive motion briefing schedule on January 7, 2015 (document #81). Specifically, the new deadline calls for responses to the Government's motion to dismiss by April 24, 2015. In addition, the Government's reply shall be filed by no later than May 22, 2015. After review of the Magistrate Judge's order, this court set a new hearing date for June 19, 2015, at 9:00 a.m. (document #82). As a result, the parties hereby comply with the case management conference deadline and submit this statement. Due to the new extended briefing schedule and decision regarding the prior dispute, the parties jointly propose continuing the January 16, 2015 Case Management Conference hearing until March 6, 2015.

Discovery

The parties are currently engaging in written discovery and document production. This process is detailed within the September 26, 2014 Joint Case Management Conference Statement previously submitted to the Court. In addition, both Plaintiffs and the DNC Defendants have also noticed the depositions of the United States' person(s) most qualified. The United States agreed to produce deponents in response to these demands. The second rescheduled deposition dates of the identified deponents were tentatively set for January 14-16, 2015 (a time close to the upcoming case management conference), but these dates have been altered by the order on DNC defendants' motion to extend time (document #81). The parties are in the process of resetting all currently noticed depositions to meet with the Court's scheduling order. To promote efficiency and conserve resources, the parties propose continuing the January 16, 2015 Case Management Conference hearing until March 6, 2015 until a time when the parties will be in the judicial district completing the rescheduled depositions of the identified deponents.

Professional Conduct

The parties have reviewed the revised judges' uniform standing order and reviewed the Guidelines for Professional Conduct for the Northern District of California prior to submitting this proposed order.

IT IS SO STIPULATED.

SO ORDERED. Further, the parties shall file a Joint Case Management Statement no later than February 27, 2015.