STIPULATION AND [PROPOSED] ORDER MODIFYING BRIEFING SCHEDULE FOR MOTION TO DISMISS

RICHARD SEEBORG, District Judge.

WHEREAS, on July 31, 2017, in accordance with the Court's June 30, 2017, Consolidation Order, Plaintiffs designated the complaint filed in Liss v. Schulman, et al., Case No. 5:17-cv-02446-as the operative complaint in this Consolidated Derivative Action (the "Operative Complaint");

WHEREAS, on September 28, 2017, nominal defendant PayPal Holdings, Inc. ("PayPal") filed a motion to dismiss Plaintiffs' Operative Complaint ("MTD"), along with a request for judicial notice in support thereof ("RJN");

WHEREAS, pursuant to the Consolidation Order, the deadline for Plaintiffs to file response(s) to PayPal's MTD and RJN is November 13, 2017;

WHEREAS, the parties have conferred regarding the current briefing schedule for Plaintiffs' response(s) to PayPal's MTD and RJN and, in light of certain unanticipated scheduling issues on the part of Plaintiffs' counsel, have agreed to a short extension of time for Plaintiffs' response(s); and

WHEREAS, should the Court not enter an order consistent with this stipulation, defendants will not argue that Plaintiffs failed to timely file their response brief(s), to the extent Plaintiffs are relying on the parties' agreement in this stipulation;

NOW, THEREFORE, the undersigned parties hereby stipulate and agree, and respectfully request that the Court enter an order as follows:

1. Plaintiffs' response(s) to PayPal's MTD and RJN shall be filed no later than November 16, 2017.

2. PayPal's reply brief(s) shall be filed no later than December 7, 2017.

3. The hearing on PayPal's MTD shall remain set for December 14, 2017.

SIGNATURE ATTESTATION

I, Shane P. Sanders, am the ECF user whose identification and password are being used to file the foregoing Stipulation and [Proposed] Order Modifying Briefing Schedule for Motion to Dismiss. In compliance with Civil L.R. 5-1(i)(3), I hereby attest that concurrence in the filing of this document has been obtained.

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ORDER

Based on the Stipulation of the signed parties, and good cause appearing, IT IS HEREBY ORDERED that the Stipulation is approved. The hearing is hereby continued to 12/21/2017 at 1:30

It is so ORDERED.