STIPULATION AND [PROPOSED] ORDER TO VACATE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES AND TO SET BRIEFING SCHEDULE

VINCE CHHABRIA, District Judge.

WHEREAS, Plaintiffs Lynn Morris, Caroline Plaza, Veronica Tench, Jacqueline Murray, Maidaflor Maybir, Jocelyn Manacmul, Donna Gutierrez, Eleanore de Dios, and Elenita Santos-Funai (collectively, the "Plaintiffs") filed the Complaint in this civil action on October 21, 2014.

WHEREAS, on November 18, 2014, the Plaintiffs and Defendants Daughters of Charity Health System, Daughters of Charity of St. Vincent De Paul Province of the West, Daughters of Charity Ministry Services Corporation, Robert Issai, Stephanie Battles, and Mike Stuart (collectively, the "Defendants") filed a stipulation extending the time for Defendants to answer or otherwise respond to Plaintiffs' Complaint to December 31, 2014.

WHEREAS, on December 26, 2014, the Plaintiffs and the Defendants filed a stipulation extending the time for the Defendants to file a Motion to Dismiss, Motion to Stay, Answer or otherwise respond to Plaintiffs' Complaint to January 15, 2015.

WHEREAS, the Defendants filed a Motion to Stay on January 15, 2015. WHEREAS, the initial Case Management Conference ("CMC") in this case is set for

January 29, 2015, and certain associated deadlines (involving the Joint Case Management Statement, the Proposed Case Management Order, and the Rule 26(f) Report) are set for January 20, 2015.

WHEREAS, counsel for the Plaintiffs and counsel for the Defendants have conferred and agreed that it is in the best interests of all parties and would promote judicial efficiency to vacate the CMC and associated deadlines until the Motion to Stay is resolved and to set a schedule for the briefing and hearing of the Motion to Stay, except both parties agree to exchange initial disclosures by January 22, 2015. While Plaintiffs reserve the right to move for a preliminary injunction and for early discovery, Defendants will oppose injunctive relief and/or early discovery for reasons including, but not limited to, those stated in the Motion to Stay and under the Federal Rules of Civil Procedure.

NOW, THEREFORE, the Plaintiffs and the Defendants, by and through their respective counsel, hereby stipulate as follows:

Plaintiffs' opposition to the Motion to Stay shall be filed no later than February 12, 2015.

Defendants' reply in support of the Motion to Stay shall be filed no later than February 19, 2015.

The Motion to Stay shall be heard on March 12, 2015.

The CMC currently set for January 27, 2015 and all associated deadlines are vacated, except parties shall exchange initial disclosures on January 22, 2015.

The CMC is rescheduled for March 24, 2015.

Respectfully submitted.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED