JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CASE DEADLINES

LAUREL BEELER, District Judge.

ADDITIONAL COUNSEL

STIPULATION

WHEREAS, Plaintiffs Vlad Tsyn, Catherine Horan-Walker, Daniel Silbermann ("Plaintiffs") bring this action against Defendant Wells Fargo Advisors, LLC ("WFA") alleging putative class action claims under California law as well as individual claims under the federal Fair Labor Standards Act ("FLSA");

WHEREAS, Plaintiffs initially pursued their FLSA claims on a putative collective action basis, but in light of the Court ruling on WFA's motions for partial summary judgment, Plaintiffs, reserving their appellate rights, have confirmed that they will not be pursuing certification of the putative collective action in this case, and so Plaintiffs' still pending FLSA claims will proceed on an individual basis only, and there is no need to schedule conditional certification proceedings;

WHEREAS, on August 11, 2016, this Court held a Further Case Management Conference during which conference the Court established certain deadlines, including the deadlines for a Motion re: Class Certification (currently set for February 9, 2017) (ECF No. 145);

WHEREAS, the Parties are still engaged in discovery pertinent to the anticipated litigation of the propriety of class certification, including taking a multi-topic deposition under Fed. R. Civ. Pro. 30(b)(6), which was delayed due the witness' schedule and then again because, on the date of the deposition, Plaintiffs' counsel's flight was cancelled due to severe weather;

WHEREAS, the Parties agree, as in the past, to meet and confer following the filing of any motion to attempt to agree on a briefing and hearing schedule and, if needed, then submit any resulting dispute to the Court;

WHEREAS, the Parties have requested extensions of the case deadlines in the past;

WHEREAS, in order to preserve the time and resources of the Court and of the Parties while the Parties continue to engage in discovery, good cause exists to continue the class certification briefing and other case deadlines; and,

WHEREAS, the Parties would be happy to attend an in person or telephonic scheduling conference with the Court if the Court has any concerns about the schedule set forth in this Stipulation;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the respective Parties hereto, that, as the Court's schedule permits, the current schedule be adjusted as follows:

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

FILER'S ATTESTATION

Pursuant to Local Rule 5-1(i)(3), regarding signatures, I attest that concurrence in the filing of the document has been obtained from each of the other signatories listed above.

[PROPOSED] ORDER

Pursuant to the Parties' Joint Stipulation, it is hereby ORDERED that the case deadlines in this matter be continued as follows: