STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE (L.R. 6-2)

EDWARD M. CHEN, District Judge.

Pursuant to Civil Local Rule 6-2, Plaintiffs John Doe One, John Doe Two, John Doe Three, John Doe Four, and John Doe Five (collectively, "Plaintiffs"), and Defendants CVS Pharmacy, Inc., Caremark, L.L.C., Caremark California Specialty Pharmacy, L.L.C. (collectively, "CVS"), National Railroad Passenger Corporation d/b/a Amtrak ("Amtrak"), Lowe's Companies, Inc. ("LCI"), and Time Warner, Inc. ("Time Warner") (collectively, CVS, Amtrak, LCI, and Time Warner are "Defendants"), by and through their undersigned counsel, do hereby stipulate as follows:

WHEREAS, the Initial Case Management Conference is currently set for August 16, 2018 at 9:30 a.m.;

WHEREAS, briefing on Defendants' respective motions to dismiss Plaintiffs' Amended Complaint will not be completed by August 16, 2018;

WHEREAS, the parties have stipulated and requested that the hearing on Defendants' respective motions to dismiss be held on September 27, 2018 at 1:30 p.m., and the Court has granted that request (see ECF No. 102);

WHEREAS, Amtrak's lead counsel, Brian Shaffer, is unavailable on August 16, 2018 due to a previously scheduled vacation and Amtrak's other senior lawyer, Elise Attridge, will be unavailable due to maternity leave;

WHEREAS, counsel for Plaintiffs, CVS, and Amtrak have previously met and conferred to discuss the matters covered in the Initial Case Management Conference statement, and have circulated drafts of that statement, but additional defendants LCI and Time Warner have been added to this case via Plaintiffs' Amended Complaint since then;

WHEREAS, the parties have met and conferred and stipulated to continue the Initial Case Management Conference;

WHEREAS, the parties respectfully request that the Initial Case Management Conference be continued to September 27, 2018 immediately after the hearing on Defendants' respective motions to dismiss, or, alternatively, continued to September 13, 2018 at 9:30 a.m.;1 and

WHEREAS, the parties agree that they will file a joint Initial Case Management Conference statement one week before the Initial Case Management Conference.

THEREFORE, the parties, by and through their counsel of record, hereby stipulate to the above and request that the Court continue the Initial Case Management Conference from August 16, 2018 to September 27, 2018 immediately after the hearing on Defendants' respective motions to dismiss, or, alternatively, to September 13, 2018 at 9:30 a.m.

ECF ATTESTATION

Pursuant to L.R. 5-1(i)(3), Ellie F. Chapman hereby attests that concurrence in the filing of this document has been obtained from all signatories.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.