STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO FILE MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT

EDWARD M. CHEN, District Judge.

Pursuant to Civil Local Rule 7-12, Plaintiffs Peter Wright and Michelle Trame ("Plaintiffs") and Defendants Adventures Rolling Cross Country, Inc. ("ARCC") and Scott von Eschen ("Defendants"), by and through their attorneys of record, make the following stipulated request regarding the briefing deadline for Plaintiffs' impending Motion for Final Approval of Class Action Settlement, as follows:

WHEREAS, the Court initially set a Final Approval Hearing for January 16, 2013, and a deadline of November 28, 2013 for Plaintiffs' Motion for Final Approval;

WHEREAS, on November 19, 2013, the Court re-set the Final Approval Hearing Date for January 23, 2013;

WHEREAS, although the initial deadline for Class Members to postmark their Opt-in Forms in this class action was November 25, 2013, the Parties and the Claims Administrator extended that deadline to December 2, 2013, due to an error by the Claims Administrator causing a one-week delay in the provision of correct Notice Forms to the Class Members; as such, the Parties expect valid claims to continue to be submitted to the Claims Administrator through December 2, 2013;

WHEREAS, in light of the deadline for submission of Claims forms, the Parties respectfully request to delay the deadline for submission of the Final Approval Motion, to allow the Final Approval Motion to describe accurately the Class Members' participation in the settlement;

WHEREAS, in light of the Court's continuance of the Final Approval Hearing date, there would be no prejudice to any party or the Court if the deadline for the Final Approval Motion were continued;

THEREFORE IT IS HEREBY STIPULATED AND REQUESTED by and between Plaintiffs and Defendants, through their respective counsel, that the Court continue the deadline for filing a Final Approval Motion to December 9, 2013, by which time all claims will have been submitted.

[proposed] ORDER

Pursuant to the stipulation, it is SO ORDERED.