STIPULATED REQUEST FOR ORDER CHANGING TIME TO RESPOND TO PLAINTIFFS' COMPLAINT AND TO MODIFY BRIEFING SCHEDULE

KANDIS A. WESTMORE, Magistrate Judge.

Pursuant to Civil Local Rules 6-1(b) and 6-2 of the Northern District of California, plaintiff Patricia Jordan ("plaintiff") and defendants the Presidio Trust and the U.S. Equal Employment Opportunity Commission (collectively, "defendants"), by and through their respective counsel, respectfully submit this stipulated request to: (1) extend the time for defendant to respond to plaintiffs' Complaint, and (2) modify the briefing schedule for defendants' anticipated motion to dismiss as follows, as follows:

1. Defendants intend to respond to plaintiff's Complaint by filing a motion to dismiss. Under the current schedule, defendants' response (motion) is due on September 16, 2016; plaintiff's opposition to the motion is due two weeks later, on September 30, 2016; and defendants' reply is due the following week, on October 7, 2016;

2. The parties agree that the briefing schedule should be modified due to the anticipated complexity of defendants' forthcoming motion, which defendants represent will raise jurisdictional issues and will also argue that plaintiff has failed to state a claim upon which relief will be granted. The commentary to the Civil Local Rules instructs that the default two weeks for an opposition and one week for a reply "are minimum time periods," and that for "complex motions," such as the one that defendants anticipate filing here, "parties are encouraged to stipulate or seek a Court order establishing a longer notice period with correspondingly longer periods for response or reply." Civil. L.R. 7-2 Commentary.

3. In addition, defendants represent that their motion must be reviewed by multiple federal agencies before it can be filed, and additional time is needed due to the press of business. Similarly, the press of business informs the parties' agreement that the timeframes for the opposition and the reply should be enlarged, since counsel for the parties must also continue their work on other matters during the time allowed for the briefing here.

4. For these reasons, the parties request that the Court enter the following stipulated briefing schedule: defendants' motion to dismiss due by Monday, September 26; plaintiffs' opposition due by Friday, November 4; defendants' reply due by Thursday, Nov. 17.

5. The requested briefing schedule will alter the current deadline (of September 16) for defendants' response to the Complaint. One prior extensions of time has previously been requested and granted; on August 30, 2016, the Court granted defendants' request to extend the deadline for responding to the Complaint. See ECF No. 30.

6. The requested time modification will not alter any other event or deadline. The next case management conference in this case is scheduled for November 29, 2016 at 1:30pm, and the parties are to file a Case Management Statement by November 22.

IT IS SO STIPULATED AND REQUESTED.