JOINT STIPULATION FOR A 15-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 15-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. By Order dated February 13, 2015, the Court permitted the Plaintiffs to file a new motion for settlement approval by March 18, 2015.

3. The Court further vacated the Case Management Conference set for March 11, 2015, and set a Case Management Conference for April 8, 2015 in the event that Plaintiffs do not file their Motion for Settlement Approval by March 18.

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 believe that they are close to reaching a new agreement but feel they would benefit from a further brief extension to resolve the few remaining issues and prepare their briefs in support of the new proposed agreement.

Accordingly, the parties respectfully request that the deadline for submission be extended by 15 days to April 1, 2015; that the April 8, 2015, date currently set for the Case Management Conference be vacated; and that a Case Management Conference be set for a later date.

[PROPOSED] ORDER

Good cause appearing, the foregoing Joint Stipulation for a 15-Day Extension of Time to File New Motion for Settlement Approval is hereby approved in part, and it is hereby ordered that:

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

2. The Case Management Conference currently set for April 8, 2015 is vacated;

3. In the event Plaintiffs do not file a motion by April 1, 2015, a Case Management Conference is set for April 8, 2015 at 2:00 p.m. The parties' Case Management Statement will be due by April 2, 2015.

PURSUANT TO STIPULATION, IT IS SO ORDERED.