JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING PRELIMINARY APPROVAL DEADLINES BY ONE WEEK

JON S. TIGAR, District Judge.

TO THE HONORABLE COURT AND THE CLERK OF THE COURT:

Pursuant to Civil Local Rule 6-2, Plaintiffs Julian Mena, Todd Schreiber, Nate Coolidge, Ernesto Mejia, and Byron McKnight (collectively, "Plaintiffs") and Defendants Uber Technologies, Inc. and Rasier, LLC (collectively "Defendants") (collectively with Plaintiffs, the "Parties") respectfully request that this Court extend the deadlines set forth in the April 25, 2017 Scheduling Order by one week to allow the Parties to complete their updates and revisions to the settlement documents.

The Parties have agreed to a new class definition, a new method of allocating the settlement between class members, and a new process for class members to receive their share of the settlement, each of which requires careful revision to the settlement documents. In addition, the Parties have reached a new agreement with a settlement administrator that will reduce administrative and distribution costs to the class by several hundred thousand dollars, but need to update the settlement documents to reflect that new process. Plaintiffs also need additional time to map the damages analysis in their preliminary approval motion to the new class size and the revised calculations based on the settlement structure and administrative cost changes. The Parties thus seek one additional week to ensure that they can fully implement the agreed upon changes in the settlement documents.

By and through their respective counsel of record, the Parties hereby stipulate and request that the Court enter an Order as follows:

WHEREAS, Plaintiffs commenced this action on January 6, 2015 [Dkt. 1];

WHEREAS, on February 11, 2016, Plaintiffs filed a Motion for Preliminary Approval of Class Action Settlement (herein the "Motion") [Dkt. 75-4];

WHEREAS, on August 30, 2016, the Court issued its Order Denying Motion For Preliminary Approval Of Class Action Settlement (herein the "Denial Order") [Dkt. 98];

WHEREAS, since the date of the Denial Order, the Parties have engaged in multiple mediation and settlement sessions;

WHEREAS, the Parties attended a settlement conference before the Honorable Chief Magistrate Judge Joseph C. Spero on March 7, 2017;

WHEREAS, the Court entered a Scheduling Order on April 25, 2017 that set a May 25, 2017 deadline for Plaintiffs' motion for preliminary approval of settlement, a June 8, 2017 deadline for Defendants' memorandum in support of preliminary approval, and a June 29, 2017 date for the preliminary approval hearing [Dkt. 121];

WHEREAS, the Parties have agreed to, inter alia, a new class definition and a new method of allocating settlement payments among class members, both of which change the structure of the settlement and require extensive revisions to the settlement documents;

WHEREAS, the Parties have negotiated a new process for class members to receive their share of the settlement, and have reached an agreement with a settlement administrator that will reduce administrative and distribution costs to the class by several hundred thousand dollars, but need to update the settlement documents to reflect that new process;

WHEREAS, Plaintiffs need additional time to map the damages analysis in their preliminary approval motion to the new class size and the revised calculations based on the settlement structure and administrative cost changes;

WHEREAS, the Parties would greatly benefit from an additional week to fully implement the above revisions in the settlement documents; and

WHEREAS, no trial date has been set for this case;

NOW THEREFORE, in consideration of the foregoing, the Parties, by and through their undersigned counsel, hereby stipulate, agree subject to Court approval, and request that the Court enter an Order extending the deadlines in the April 25, 2017 Scheduling Order by one week, as set forth in the accompanying Proposed Order.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Pursuant to the Parties' May 23, 2017 Stipulation, the Court hereby sets the following case deadlines pursuant to Federal Rule of Civil Procedure 16:

The Court will set a further case management conference if preliminary approval is denied to set the remaining deadlines in the case.

PURSUANT TO STIPULATION, IT IS SO ORDERED.