STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND DEFENDANTS' TIME TO FILE RESPONSIVE PLEADING

EDWARD M. CHEN, District Judge.

Pursuant to Local Rule 6-2, Plaintiffs RONALD GILLETTE and ABDUL KADIR MOHAMED and Defendants UBER TECHNOLOGIES INC., RASIER, LLC and HIREASE, LLC (collectively, the "Parties") hereby stipulate to extend the deadline for Defendants to respond to the complaints until 14 days after the anticipated stipulated filing of Plaintiffs' consolidated complaint, or if the Parties are unable to agree on a stipulation for the filing of same, until 7 days after the Court rules on Plaintiffs' motion for leave to file a consolidated complaint. This Stipulation is based on the following:

1. The current deadline for Defendants to respond to the operative complaints in Mohamed v. Uber Technologies, Inc., et al. and Gillette v. Uber Technologies, Inc., et al. is July 9, 2015.

2. Plaintiffs previously indicated in the Joint Case Management Conference Statement (Mohamed Docket No. 56; Gillette Docket No. 34) that they would consider filing a consolidated complaint if the Court were to deny Defendants' motions to compel arbitration.

3. Plaintiffs have now requested that Defendants stipulate to the filing of a consolidated complaint. The Parties are currently meeting and conferring regarding whether consolidation is appropriate and, if so, the terms of a stipulation regarding consolidation and the filing of a consolidated complaint. The Parties expect to submit to the Court a stipulation regarding consolidation, if any, within 14 days.

4. This request is not made by the Parties 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 respond to the complaint. Defendants Uber Technologies, Inc. and Rasier, LLC and Plaintiff Mohamed previously stipulated to two extensions of Defendants' time to respond to the complaint. Defendant Hirease, LLC and Plaintiff Mohamed previously stipulated to one extension of Hirease's time to respond to the complaint.

5. Nothing stated in or implied by this Stipulation and Proposed Order is intended to or shall affect Plaintiffs' right, if any, to amend their complaints in accordance with Federal Rule of

6. Nothing stated in or implied by this Stipulation and Proposed Order is intended to or shall affect any of the Parties' rights, arguments or positions with regard to the Parties' dispute concerning arbitration or any other rights of the Parties.

THEREFORE, the parties to this Stipulation hereby stipulate and respectfully request as follows: that the Court extend the deadline for Defendants to respond to the complaints until 14 days after the anticipated stipulated filing of Plaintiffs' consolidated complaint, or if the Parties are unable to agree on a stipulation for the filing of same, until 7 days after the Court rules on Plaintiffs' motion for leave to file a consolidated complaint.

PURSUANT TO STIPULATION, IT IS SO ORDERED.