STIPULATION AND [PROPOSED] SCHEDULING ORDER OF ADR DEADLINES

WILLIAM ALSUP, District Judge.

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

WHEREAS, on April 27, 2016 an Initial Case Management Scheduling Order with ADR Deadlines was entered in the case captioned Cobalt Partners, L.P. v. SunEdison, Inc. et al., 3:16-cv-2263 ("Cobalt");

WHEREAS the Initial Case Management Conference in Cobalt is set for August 18, 2016. [Dkt. 48], and the corresponding deadline to file ADR Certifications and a Notice of Need for ADR Phone Conference or Stipulation to ADR Process is July 28, 2016;

WHEREAS, on April 28, 2016 an Initial Case Management Scheduling Order with ADR Deadlines was entered in the case captioned Glenview Capital Partners, L.P. v. SunEdison, Inc. et al., 3:16-cv-2264 ("Glenview");

WHEREAS the Initial Case Management Conference in Glenview is set for August 18, 2016. [Glenview Dkt. 48], and the corresponding deadline to file ADR Certifications and a Notice of Need for ADR Phone Conference or Stipulation to ADR Process is July 28, 2016;

WHEREAS, on April 28, 2016 an Initial Case Management Scheduling Order with ADR Deadlines was entered in the case captioned Bloom v. SunEdison, Inc. et al., 3:16-cv-2265 ("Bloom");

WHEREAS the Initial Case Management Conference in Bloom is set for August 18, 2016. [Bloom Dkt. 20], and the corresponding deadline to file ADR Certifications and a Notice of Need for ADR Phone Conference or Stipulation to ADR Process is July 28, 2016;

WHEREAS, on April 27, 2016 an Initial Case Management Scheduling Order with ADR Deadlines was entered in the case captioned Omega Capital Partners L.P. v. SunEdison, Inc. et al., 3:16-cv-2268 ("Omega");

WHEREAS the Initial Case Management Conference in Omega is set for August 18, 2016. [Omega Dkt. 43], and the corresponding deadline to file ADR Certifications and a Notice of Need for ADR Phone Conference or Stipulation to ADR Process is July 28, 2016;

WHEREAS, Defendants have requested additional time to fully discuss available ADR options with their clients, many of whom are individuals, and to gather their clients' signatures;

WHEREAS, Defendants have met and conferred with Plaintiffs over the requested extension, and agreed to extend the deadline to file the ADR Certifications and a Notice of Need for ADR Phone Conference or Stipulation to ADR Process until August 11, 2016;

WHEREAS, the agreed extension 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, and Defendants' deadlines to respond in Omega and Glenview were further extended by grant of Defendants' Administrative Motions to Extend Time, and 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;

WHEREAS, the Court has previously ordered, pursuant to stipulation, an extension of time to file opposition and reply briefs to Defendants' motions to transfer in Bloom, Cobalt, Omega, and Glenview, and Plaintiffs' motions to remand in Bloom, Cobalt, Omega, and Glenview;

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

NOW THEREFORE, the parties hereby agree, and request the court to order that:

PURSUANT TO STIPULATION, IT IS SO ORDERED.