JOINT STIPULATION AND ORDER SETTING A SCHEDULE FOR DISSEMINATION OF NOTICE AND FINAL APPROVAL

HAYWOOD S. GILLIAM, Jr., District Judge.

Plaintiff Patrick Hendricks ("Plaintiff") and Defendant StarKist Co. ("Defendant") (collectively, the "Parties"), by and through their respective counsel of record, enter into the following stipulation, based upon the recitals below:

WHEREAS, the Court granted preliminary approval of the Parties' proposed class action settlement on July 23, 2015;

WHEREAS, in its Order Granting Preliminary Approval, the Court instructed the Parties to submit a proposed schedule for (i) the completion of dissemination of notice, (ii) the filing deadline for the attorneys' fees and costs motion, (iii) the filing deadline for the incentive payment motion, (iv) the deadline for objections, opt-outs, and claims, (v) the filing deadline for the final approval motion, and (vi) a date for a Final Fairness hearing and hearing on motions.

NOW THEREFORE, the Parties hereby stipulate, subject to Court approval, to jointly recommend the following proposed schedule leading to a Final Fairness hearing and hearing on motions:

1. Dissemination of notice shall be completed by September 25, 2015;

2. Class counsel shall file their application for attorneys' fees, reimbursement of expenses, and approval of incentive awards by October 30, 2015;

3. The deadline for the submission of claim forms, opt-outs, and objections shall be November 20, 2015;

4. The Parties may file responses to objections and move for final approval by December 11, 2015; and

5. The Court shall hold a Final Fairness hearing and hearing on motions on December 17, 2015 at 2:00 p.m., or as soon thereafter as the Court is available.

IT IS SO STIPULATED.

ATTESTATION

Pursuant to Civil Local Rule 5-1, I, Scott A. Bursor, attest that all signatories listed, and on whose behalf the filing is submitted, concur in the stipulation's content and have authorized the stipulation.

PURSUANT TO STIPULATION, IT IS SO ORDERED.