STIPULATION AND SCHEDULING ORDER

WILLIAM H. ORRICK, 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 July 2, 2018, Defendants filed their combined Motion to Dismiss the First Amended Complaint ("FAC"), noticed for hearing on August 15, 2018 at 2:00 pm;

WHEREAS, Plaintiffs' opposition to the MTD currently is due on or before July 16, 2018, and Defendant's reply is due on or before July 23, 2018;

WHEREAS, Plaintiffs have asked Defendants to agree to an extension of time to respond to Defendant's motion to dismiss the FAC in light of a number of complex issues raised in Defendant's motion to dismiss the FAC that will require careful research by Plaintiffs in preparing their response;

WHEREAS, Plaintiffs' counsel was involved in a serious automobile accident on June 24, 2018, which has altered his ability to meet the current deadline;

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 25, 2018 to file their opposition to the motion to dismiss the FAC, and (2) Defendants to and including August 20, 2018 to file their reply in support of their motion to dismiss the FAC;

WHEREAS, the agreed schedule is designed to accommodate various counsels' scheduled travel over the summer;

WHEREAS, the agreed schedule will alter the date of the hearing that is currently set for August 16, 2018. The parties propose that the hearing be reset for September 5, 2018 at 2:00 pm.

WHEREAS, no other extensions of time have been granted concerning the instant motion to dismiss the FAC;

ATTACHED as exhibit "A" to this stipulation is the declaration of Keith Altman, Esq. in support of the stipulation.

NOW THEREFORE, the parties hereby agree and stipulate to the following schedule:

Counsel's Stipulation is adopted with the modification that hearing will be set on September 12, 2018 at 2:00 p.m.