JOINT STIPULATION TO ENLARGE TIME RE MOTION TO DISMISS AND INITIAL CASE MANAGEMENT; [PROPOSED] ORDER

WILLIAM H. ALSUP, District Judge.

Plaintiff Pop Middle East, Inc., Defendant POPSUGAR Inc., and Defendant Ebates, Inc., by and through their respective counsel of record, stipulate as follows:

WHEREAS, Plaintiff Pop Middle East, Inc. (hereinafter "Plaintiff") filed its Complaint on April 11, 2017 [Dkt 1];

WHEREAS, Plaintiff served the Complaint on Defendants POPSUGAR, Inc. and Ebates, Inc. on April 13, 2017, and a responsive pleading was due on or about May 4, 2017 [Dkts. 7-1 and 7-2];

WHEREAS, on April 21, 2017, Plaintiff agreed to extend Defendants' time to answer or otherwise respond to the complaint by 21 days, up to and including May 25, 2017 [Dkt. 11];

WHEREAS, on May 5, 2017, the Court scheduled an Initial Case Management Conference for July 13, 2017;

WHEREAS, on May 18, 2017, Plaintiff agreed to a further extension of time for Defendants to answer or otherwise plead to the complaint, up to and including June 15, 2017 [Dkt. 19];

WHEREAS, on June 15, 2017, Defendants POPSUGAR, Inc. and Ebates filed and served their motions to dismiss, with a hearing date of July 27, 2017;

WHEREAS, on June 29, 2017, Judge Alsup granted a Stipulation extending the deadline (i) for the Plaintiff's time to file its opposition to Defendants' motions to dismiss to July 31, 2017; (ii) for Defendants' replies to August 7, 2017, and continuing the deadline for (iii) the hearing date on Defendants' motions to dismiss to August 17, 2017; and (iv) the date for the Initial Case Management Conference to August 17, 2017 [Dkt.34].

WHEREAS, Plaintiff's oppositions to the motions to dismiss are due in three (3) days, on July 31, 2017.

WHEREAS, Plaintiff and Defendant POPSUGAR, Inc. have reached agreement on all terms of a fully drafted and final settlement agreement, except that execution is dependent upon Plaintiff and Defendant Ebates completing their separate settlement agreement.

WHEREAS, Plaintiff and Defendant Ebates have exchanged multiple drafts of a separate settlement agreement, have substantially completed the negotiations relating to all terms and require additional time to agree on a final draft before signature;

WHEREAS, the Parties are confident that with the extra time requested, the settlement agreements will be fully executed;

WHEREAS, in order to facilitate the remaining settlement negotiations and full execution (signing) of the settlement agreements, the parties have agreed to extend the deadlines by seven (7) days (i) for Plaintiff's oppositions to Defendants' motions to dismiss to August 7, 2017, (ii) for Defendants' replies to August 14, 2017, (iii) to continue the hearing date on Defendants' motions to dismiss to August 24, 2017 at 8:00 a.m, or to such other date as the court has available; and (iv) request that the Initial Case Management Conference be continued from August 17, 2017 at 11:00 a.m to a future date, along with the F.R.C.P. Rule 26(f) deadlines;

WHEREFORE, pursuant to Civil Local Rule 6-2, the parties stipulate and agree that:

1. Plaintiff's time to file its opposition to Defendants' motions to dismiss shall be extended to August 7, 2017;

2. Defendants' time to file its replies shall be extended to August 14, 2017;

3. That the hearing on Defendants' motions to dismiss be continued to August 24, 2017 at 8:00 a.m., or to such other date as the Court has available; and

4. That the currently scheduled Initial Case Management Conference set for August 17, 2017 at 8:00 a.m., also be continued to August 24, 2017, or to such other date as the Court has available.

[PROPOSED] ORDER GRANTING STIPULATION

PURSUANT TO STIPULATION, IT IS ORDERED that:

1. Plaintiff's time to file its opposition to Defendants' motions to dismiss shall be extended from July 31, 2017 to August 7, 2017;

2. Defendants' time to file its replies shall be extended from August 7, 2017 to August 14, 2017;

3. That the hearing on Defendants' motions to dismiss be continued from August 17, 2017 at 8:00 a.m. to August 24, 2017 at 8:00 a.m., or to ______________;

4. That the Initial Case Management Conference set for August 17, 2017 at 8:00 a.m. be continued to August 24, 2017, or to ___________, along with the F.R.C.P. Rule 26(f) deadlines.

IT IS SO ORDERED.