JOINT STIPULATION AND [PROPOSED] ORDER FOR TEMPORARY STAY PENDING MEDIATION

JON S. TIGAR, District Judge.

Plaintiffs Matthew Philliben and Byron McKnight ("Plaintiffs") and Defendants Uber Technologies, Inc. and Raiser, LLC ("Uber") (collectively with Plaintiffs, the "Parties"), respectfully move this Court to enter a stipulation staying the current litigation for 60 days due to pending settlement negotiations between the Parties. In support of this stipulation, the Parties state:

WHEREAS, in order to resolve this dispute, the Parties are engaging in settlement negotiations and believe that a compromise can be reached;

WHEREAS, the Parties have scheduled a mediation session with the Hon. Carl J. West (Ret.) for August 4, 2015;

WHEREAS, in order to facilitate the Parties' settlement discussions, the Parties request and stipulate to a 60 day stay of the case and all currently scheduled hearings and deadlines;

WHEREAS, the Parties jointly desire to avoid further expenditure of the Court's resources or their own resources on this litigation pending completion of the agreed-upon mediation;

WHEREAS, no Scheduling Order has been entered for the case;

WHEREAS, the hearing on Uber's Motion to Stay Proceedings Pending Arbitration is currently scheduled for July 2, 2015;

WHEREAS, a Case Management Conference is currently scheduled for July 22, 2015;

NOW, THEREFORE, IN CONSIDERATION OF THE FOREGOING, IT IS HEREBY STIPULATED by and between the Parties that, subject to Court approval, all scheduled deadlines and hearings be continued for 60 days pending mediation between the Parties; the currently scheduled July 2, 2015 hearing on the Motion to Stay Proceedings Pending Arbitration be continued until at least August 27, 2015; the currently scheduled July 22, 2015 Case Management Conference be continued until at least September 16, 2015; and the parties will file a Joint Statement regarding the status of the settlement following the mediation.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, THE COURT ORDERS AS FOLLOWS:

All scheduled deadlines and hearings are continued for 60 days pending mediation between the Parties. The currently scheduled July 2, 2015 hearing on the Motion to Stay Proceedings Pending Arbitration is continued until August 27, 2015. The currently scheduled July 22, 2015 Case Management Conference is continued until September 16, 2015, and the parties' deadline to file a Case Management Statement and act under Federal Rule of Civil Procedure 26, including the conference of the parties pursuant to Rule 26(f) and initial disclosures under Rule 26(a), are extended accordingly and discovery shall remain stayed. The parties will update the Court on the status of the settlement following the mediation.