STIPULATION TO CONTINUE MOTION FOR CLASS CERTIFICATION AND COLLECTIVE ACTION BRIEFING AND HEARING SCHEDULE; ORDER (MODIFIED)

RICHARD SEEBORG, District Judge.

STIPULATION

Plaintiffs Joan Ambrosio, et al. ("Plaintiffs") and Defendant Cogent Communications, Inc. ("Defendant") (collectively, the "Parties"), through their counsel, hereby stipulate and agree that:

WHEREAS the Parties have engaged in significant discovery to date;

WHEREAS the Parties continue to exchange documents responsive to various discovery requests, and continue to meet and confer to resolve disputes with respect to some of those requests;

WHEREAS the Parties continue to take depositions relevant to the class certification, some of which have been delayed due to scheduling matters but will take place over the next two weeks;

WHEREAS, due to the above, the Parties respectfully request that the Court continue the briefing and hearing schedule as detailed below which represents a five-week continuance of all dates from the current schedule;

WHEREAS, the Parties also propose that the Court continue the Case Management Conference, currently set for October 22, 2015, to the same date as the hearing on Plaintiffs' motion.

NOW, THEREFORE, the Parties, through their respective counsel, hereby stipulate, subject to the approval of the Court, to the following schedule:

ORDER (MODIFIED)

PURSUANT TO STIPULATION, the following revised schedule for Plaintiffs' Class and Collective Certification Motion is:

IT IS SO ORDERED.