STIPULATION AND [PROPOSED] SCHEDULING ORDER

WILLIAM ALSUP, District Judge.

Pursuant to Civil Local Rules 6-2(a) and 7-12, the parties,1 by and through their respective undersigned counsel of record, submit the following stipulation and proposed order:

WHEREAS, March 28, 2016, the action captioned Cobalt Partners, LP, et al. v. SunEdison, Inc. et al. ("Cobalt") was filed in Superior Court of California, San Mateo County;

WHEREAS, on March 29, 2016, the action captioned Glenview Capital Partners, L.P. et al. v. SunEdison, Inc. et al. ("Glenview") was filed in the Superior Court of California, San Mateo County;

WHEREAS, on March 30, 2016, the action captioned Omega Capital Investors, L.P. et al. v. SunEdison, Inc. et al. ("Omega") was filed in the Superior Court of California, San Mateo County;

WHEREAS, on April 4, 2016, the action captioned Bloom et al. v. SunEdison, Inc. et al. ("Bloom") was filed in the Superior Court of California, San Mateo County;

WHEREAS, on April 26, 2016, Defendants removed Bloom, Cobalt, Glenview, and Omega to federal court;

WHEREAS, on May 26, 2016, Plaintiffs moved to remand Bloom, Cobalt, Glenview, and Omega to state court [Bloom Dkt. 16; Cobalt Dkt. 53-54; Glenview Dkt. 41-42; Omega Dkt. 40-41];

WHEREAS, on May 27, 2016, Defendants moved to transfer Glenview and Bloom to the Southern District of New York [Glenview Dkt. 43; Bloom 17-18];

WHEREAS, on June 1, 2016, Defendants moved to transfer Cobalt and Omega to the Southern District of New York [Cobalt Dkt. 58-59; Omega Dkt. 45];

WHEREAS, Plaintiffs' motions to remand Cobalt, Omega, and Glenview, and Defendants' motions to transfer Cobalt and Omega are scheduled to be heard on August 18, 2016 at 8:00 a.m.;

WHEREAS, Defendants intend to re-notice their motions to transfer Glenview and Bloom for August 18, 2016 at 8:00 a.m., and Plaintiffs in Bloom intend to re-notice their motion to remand Bloom for August 18, 2016 at 8:00 a.m.;

WHEREAS, pursuant to N.D. Cal. Civ. L.R. 7-3, Defendants' responses to the motions to remand are due by June 9, 2016, and Plaintiffs' replies are due by June 16, 2016;

WHEREAS, pursuant to N.D. Cal. Civ. L.R. 7-3, Plaintiffs' response to the motions to transfer Glenview and Bloom are due by June 10, 2016, and Defendants' replies are due by June 17, 2016;

WHEREAS, pursuant to N.D. Cal. Civ. L.R. 7-3, Plaintiffs' responses to the motions to transfer Cobalt and Omega are due by June 15, 2016, and Defendants' replies are due by June 22, 2016;

WHEREAS, Defendants' deadline to respond to the Complaint in Omega is July 1, 2016 [Omega Dkt. 35];

WHEREAS, Defendants are not required to plead or otherwise respond to the Complaint in Glenview until after the motion to remand and the motion to transfer venue are decided [Glenview Dkt. 38];

WHEREAS, by agreement of the parties, Defendants are not required to plead or otherwise respond to the Complaint in Bloom until after the motion to remand and the motion to transfer venue are decided;

WHEREAS, due to the complexity of the issues raised in these multiple pending motions in multiple related cases, the parties have requested additional time to fully address all issues, and do so in an organized and coordinated fashion;

WHEREAS, the parties have met and conferred over the requested extension and negotiated and agreed to the briefing schedule set forth below, which provides: (1) Plaintiffs to and including July 1, 2016 to file their responses to the motions to transfer, and Defendants to and including July 1, 2016 to file their responses to the motions to remand; and (2) Plaintiffs to and including July 29, 2016 to file any reply in support of their motions to remand, and Defendants to and including July 29, 2016 to file any reply in support of their motions to transfer; (3) Defendants to and including August 12, 2016 to respond to the complaints in Omega and Glenview.

WHEREAS, the agreed schedule will not delay any scheduled hearings;

WHEREAS, Plaintiffs previously agreed to provide Defendants an extension of time to respond to the Complaints in Cobalt, Omega, and Glenview until May 20, 2016, and the Defendants' deadlines to respond in Omega and Glenview were further extended as set forth above;

WHEREAS, Plaintiffs in Bloom previously agreed that Defendants are not required to respond to the Complaint until after the motion to transfer and motion to remand are decided;

WHEREAS, the Court has previously ordered, pursuant to stipulation, an extension of time to file opposition and reply briefs to Defendants' motion to dismiss Cobalt to July 1, 2016 and July 29, 2016, respectively;

WHEREAS, no other extensions of time have been granted in these actions;

NOW THEREFORE, the parties here by agree and stipulate to the following deadlines:

PURSUANT TO STIPULATION, IT IS SO ORDERED.