STIPULATED REQUEST TO MOVEINITIALCASE MANAGEMENT CONFERENCE AND EXTEND TIME FOR SERVICE AND DEFENDANTS' TIME TO ANSWER

HAYWOOD S. GILLIAM, Jr., District Judge.

Pursuant to Civil Local Rule 6-2, the parties hereby submit their stipulated request to extend time for service and for Defendants' time to answer, and to move the initial Case Management Conference currently scheduled for January 26, 2016, at 2:00 p.m., for the following reasons:

1. This action is one of two cases filed in the above-captioned court, that involve all or a material part of the same subject matter and all, or substantially all, of the same parties as this action. This stipulated request is being simultaneously made in the other case as well (Vogt vs. CHP, et al. Case No. 15-cv-05199-JCS).

2. In both actions, Defendant, California Highway Patrol (by and through the Office of the Attorney General, State of California) received plaintiff's "Notice of a Lawsuit and Request to Waive Service of Summons," along with the Complaint, and all other required documents on December 14, 2015. Subsequently, the parties have engaged in a good faith dialogue regarding several anticipated issues, including the status and perfection of service of the Complaint on the individual defendants. The stipulated requested extension will provide the parties additional time to ensure all parties are properly served and represented for appearance in the action.

3. The parties have conferred and share an interest in an efficient and economical approach to managing this litigation, and are evaluating with their clients the possibility of engaging in early private mediation. To that end, the parties believe that moving the initial Case Management Conference and extending Defendants' time to appear and respond to the Complaint would prevent premature expenditure of resources and allow the Parties to further organize, confer on, and evaluate the two pending related actions filed in this District for efficient management.

4. Therefore, the parties stipulate and jointly request that new dates in this matter be assigned and ordered as follows:

• Service of all Defendants on or before March 1, 2016

5. There have been no previous requests or orders for time modification in the case. The requested extension of time will not appreciably delay proceedings in this action, and will enable more efficient and economical management of the litigation. No parties will be prejudiced, and all parties will remain similarly positioned to proceed without further delay.

IT IS SO STIPULATED AND REQUESTED.

PURSUANT TO STIPULATION, IT IS SO ORDERED EXCEPT THAT THE CASE MANAGEMENT CONFERENCE WILL BE HELD ON MAY 10, 2016.