JOINT STIPULATION FOR A 30-DAY EXTENSION OF TIME TO FILE NEW MOTION FOR SETTLEMENT APPROVAL AND REQUEST TO VACATE CASE MANAGEMENT CONFERENCE AND [PROPOSED ORDER]

JON S. TIGAR, District Judge.

Plaintiffs CHRISTOPHER OTEY and MARY GRETH ("Plaintiffs") and Defendants CROWDFLOWER, INC., LUKAS BIEWALD, and CHRIS VAN PELT ("Defendants"), by and through their respective counsel, hereby enter into the following Joint Stipulation for a 30-Day Extension of Time to File New Motion for Settlement Approval. Specifically, by and through this Stipulation, the parties request that the Court continue the parties' deadline for filing a renewed motion for settlement approval, up to and including March 18, 2015.

STIPULATION

1. On December 16, 2014, this Court denied Plaintiffs' Motion for Approval of Proposed Settlement without prejudice. (Doc. 210.)

2. In that Order, the Court permitted the Plaintiffs to file a new motion for settlement approval by February 16, 2015. Id.

3. The Court further stated in its Order that if Plaintiffs file a new motion for settlement approval by February 16, 2015, they may also request that the Court vacate the Case Management Conference, set for March 11, 2015, at 2:00 p.m.

4. The parties have been in regular discussion with regard to negotiating the terms of a new settlement agreement, and have been working diligently together in an effort to address the concerns expressed by the Court in the December 16, 2014, Order. The parties are committed to making a further attempt to reach agreement that will address all of the Court's concerns and, thereafter, to seeking the Court's approval of the revised agreement. Progress has been made on a number of issues; for example, the parties are in agreement to remove the provision for reversion, and are exploring options for the handling of any unclaimed funds. However, discussions are still in process, and no final agreement has yet been reached. For these reasons, the parties believe they would benefit from a 30-day extension in which to complete their negotiations and to prepare their papers in support of approval. Accordingly, the parties respectfully request that the deadline for submission be extended to March 18, 2015; that the March 11, 2015, and date currently set for the Case Management Conference be vacated; and that a Case Management Conference be set for a date in April.

[PROPOSED] ORDER

Good cause appearing, the foregoing Joint Stipulation for a 30-Day Extension of Time to File New Motion for Settlement Approval is hereby approved, and it is hereby ordered that:

1. Plaintiffs may file a new motion for settlement approval by March 18, 2015;

2. The Case Management Conference currently set for March 11, 2015 is vacated;

3. In the event Plaintiffs do not file a motion by March 18, 2015, a Case Management Conference is set for April 8, 2015 at 2:00 p.m..

PURSUANT TO STIPULATION, IT IS SO ORDERED