STIPULATED REQUEST FOR ORDER CHANGING TIME AND CONSOLIDATING MOTION TO COMPEL ARBITRATION BRIEFING; [PROPOSED] ORDER GRANTING REQUEST FOR ORDER CHANGING TIME AND CONSOLIDATING MOTION TO COMPEL ARBITRATION BRIEFING

EDWARD M. CHEN, District Judge.

This Stipulation is entered into by and between Defendants Uber Technologies, Inc. and Rasier, LLC1 through their counsel of record Littler Mendelson, P.C., Plaintiff Abdul Kadir Mohamed through his counsel of record Ahdoot & Wolfson, P.C and Plaintiff Ronald Gillette (Plaintiff in the related action Gillette v. Uber Technologies, Inc., Case No. 14-05241 EMC ["Gillette"]) through his counsel of record Goldstein, Borgen, Dardarian & Ho (collectively "the Parties"). Pursuant to Local Rule 6-2, the Parties hereby stipulate to a consolidated briefing schedule regarding Defendants' motions to compel arbitration in Gillette and the instant action ("Mohamed"). The Parties also seek to continue the March 12, 2015 case management conference date and associated deadlines.

This Stipulation is based on the following:

1. Defendant Uber Technologies, Inc. filed a motion to compel arbitration in the Gillette action on January 23, 2015 and noticed the hearing for March 12, 2015. Plaintiff Gillette's opposition is currently due for filing on February 6, 2015.

2. Defendants Uber Technologies, Inc. and Rasier, LLC intend to file a motion to compel arbitration in Mohamed on February 6, 2015.

3. The Court set a case management conference in Gillette for March 5, 2015, as well as associated case management and ADR deadlines, as set forth in the Court's Order Setting Initial Case Management Conference and ADR Deadlines. The Court subsequently continued the case management conference and associated deadlines to March 12, 2015.

4. The Court set a case management conference in Mohamed for February 26, 2015, as well as associated case management and ADR deadlines, as set forth in the Court's Order Setting Initial Case Management Conference and ADR Deadlines. The Court subsequently continued the case management conference and associated deadlines to March 12, 2015.

5. Given the overlap in legal and factual issues in the Gillette and Mohamed actions, the Parties met and conferred regarding a consolidated briefing schedule regarding Defendants' motions to compel arbitration. The Parties believe that consolidated briefing, hearing, and initial case management schedules promote efficiency and will avoid undue repetition of facts, evidence and legal argument common to both actions. The Parties agree, however, that if consolidated briefs are filed, the page limits for the consolidated opposition and reply should be enlarged to ensure sufficient space to address factual and legal arguments specific to each Plaintiff.

6. This request is not made for purposes of unnecessary delay and no party will be prejudiced by the granting of this request. Defendant Uber Technologies, Inc. and Plaintiff Gillette previously stipulated to an extension of Defendant's time to file a responsive pleading. Defendants Uber Technologies, Inc. and Rasier, LLC and Plaintiff Mohamed previously stipulated to two extensions of Defendants' time to file a responsive pleading.

THEREFORE, the parties to this Stipulation hereby stipulate and request as follows:

1. The Court order a consolidated opposition, reply and hearing with respect to Defendants' motions to compel arbitration in the Gillette and Mohamed matters.

2. The Court enlarge the consolidated opposition brief page limit to 40 pages and the consolidated reply brief page limit to 20 pages.

3. The Court set the following consolidated briefing schedule for the motion to compel arbitration previously filed in the Gillette action and the motion to compel arbitration anticipated to be filed in the Mohamed action:

4. The Court continue the March 12, 2015 case management conferences in the Gillette and Mohamed actions to April 9, 2015, and that the Court continue all associated deadlines accordingly.

SIGNATURE ATTESTATION

In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this document has been obtained from the signatories on this e-filed document.

PURSUANT TO STIPULATION, IT IS SO ORDERED