JOINT STIPULATION TO EXTEND APPLE'S TIME TO FILE DECLARATION IN SUPPORT OF FILING UNDER SEAL PURSUANT TO LOCAL RULE 79-5(e)

LUCK H. KOH, District Judge.

Plaintiffs Robert Herskowitz and Phoebe Juel ("Plaintiffs") and defendant Apple Inc. ("Apple"), by and through their undersigned counsel, stipulate as follows:

WHEREAS, on February 21, 2014, Plaintiffs filed an Administrative Motion to File Under Seal their memorandum in support of their motion for class certification, the declaration of Judd B. Grossman in support thereof ("Grossman Declaration"), and exhibits attached to the Grossman Declaration;

WHEREAS, pursuant to Local Rule 79-5(d), on February 21, 2014, Plaintiffs also conditionally filed under seal unredacted copies of their memorandum in support of their motion for class certification and the Grossman Declaration with supporting exhibits, and filed redacted copies in the public record;

WHEREAS, as reflected in the redacted copy of Plaintiffs' memorandum in support of class certification, a substantial portion of Plaintiffs' 29-page memorandum references the contents of or quotes from documents produced by Apple that were designated as "Confidential" or "Highly Confidential" under the parties' Stipulated Protective Order (ECF No. 61);

WHEREAS, the Grossman Declaration and 65 of the 70 exhibits attached thereto reference the contents of, quote from, or constitute copies of documents produced by Apple that were designated as "Confidential" or "Highly Confidential" under the parties' Stipulated Protective Order;

WHEREAS, pursuant to Local Rule 79-5(e), Apple continues to review the portions of Plaintiffs' memorandum in support of class certification and the Grossman Declaration and its supporting exhibits that contain material previously designated as "Confidential" or "Highly Confidential" and intends to file a declaration as to those portions that it believes are sealable;

WHEREAS, Plaintiffs take no position respecting whether any of the material designated by Apple as "Confidential" or "Highly Confidential" is sealable pursuant to Local Rule 79-5;

WHEREAS, pursuant to the Court's February 25, 2014 order (Dkt. No. 116), Apple has until March 7, 2014 to file its declaration to support the sealing;

WHEREAS, in light of the large volume of designated material at issue, Apple has requested, and Plaintiffs have no objection to, extending Apple's time to file a declaration as required by Local Rule 79-5(e) to March 11, 2014 to allow sufficient time for Apple's counsel to confer with personnel at Apple to determine which portions of the designated material are sealable and to prepare and file a declaration in support of the sealing of those portions;

NOW THEREFORE, the parties stipulate as follows, subject to the Court's approval:

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.