JOINT UPDATE REGARDING SETTLEMENT

SUSAN ILLSTON, District Judge.

Pursuant to the April 18, 2016 Stipulation and Order Regarding Settlement, the parties provide this update to the Court regarding the status of resolution. The parties are working diligently to finalize the agreement, including regular conference calls and frequent exchange of the many constituent documents. The parties will update the Court again on June 24, 2016 if the preliminary approval motion has not been filed by that time. The parties are sensitive to the fact that they have sought multiple extensions since filing the April 18, 2016 stipulation. Substantial progress has been made on this complex settlement, and the parties anticipate that no additional extensions may be needed.

As the parties have advised the Court in prior updates, since executing the Memorandum of Understanding on March 1, 2016, they have been working diligently to finalize the settlement and to present it to the Court for preliminary approval. This work includes, inter alia, preparing the following: the settlement agreement; the amended complaint consistent with the proposed settlement; the protocols for claims and for the remediation work that claimants are entitled to under the settlement; the documents related to the processing of claims, including claim forms; and the long and short form notices as well as the notice plan, in consultation with a notice provider. The parties have also been actively meeting and conferring on the selection of an independent claims administrator, and interviewing same.