STIPULATION AND ORDER FOR WITHDRAWAL OF PAUL HASTINGS LLP AS COUNSEL FOR DEFENDANT HOMEJOY, INC. CIVIL LOCAL RULES 7-12 & 11-15

EDWARD M. CHEN, District Judge.

STIPULATION

Defendant Homejoy, Inc. ("Homejoy"), and the law firm of Paul Hastings LLP ("Paul Hastings") hereby stipulate as follows:

Whereas, Paul Hastings has represented Homejoy in this action;

Whereas, Homejoy now knowingly and freely assents to Paul Hastings' withdrawal from the action, and withdrawal is permissible under Rule 3-700(C) of the California Rules of Professional Conduct;

Whereas, Paul Hastings has taken reasonable steps to avoid reasonably foreseeable prejudice to the rights of Homejoy pursuant to Rule 3-700(A)(2) of the California Rules of Professional Conduct, including giving due notice to Homejoy and allowing time for search of new counsel;

Whereas, Homejoy and Paul Hastings acknowledge that papers may continue to be served on Paul Hastings for forwarding purposes, unless and until Homejoy appears by other counsel;

Whereas, Paul Hastings will promptly and fully comply with Rule 3-700(D) of the California Rules of Professional Conduct and cooperate with successor counsel to ensure a smooth transition and to avoid any prejudice to Homejoy;

Whereas, Paul Hastings has also represented Homejoy in three pending California state court actions, Zenelaj, et al. v. Homejoy, Inc., Case No. CGC-15-544599 (San Francisco Superior Court); Ventura, et al. v. Homejoy, Inc., Case No. CGC-15-544750 (San Francisco Superior Court); and Malveaux-Smith, et al. v. Homejoy, Inc., Case No. 37-2015-00005070-CU-OE-CTL (San Diego Superior Court); and on July 15, 2015, Paul Hastings filed an Ex Parte Application to Withdraw from Representation of Defendant Homejoy, Inc., or in the Alternative, to Shorten Time to Hear Motion to Withdraw ("Ex Parte Application") in all three cases;

Whereas, on July 16, 2015, all three Ex Parte Applications were heard, and the San Francisco Superior Court granted Paul Hastings' motions to withdraw in Zenelaj and Ventura, and the San Diego Superior Court scheduled the motion to withdraw hearing for August 7, 2015, in Malveaux-Smith;

Whereas, all parties to this action are notified of this withdrawal through the electronic filing of this stipulation and proposed order;

IT IS THEREFORE STIPULATED, pursuant to Rules 7-12 and 11-5 of the Civil Local Rules of the United States District Court for the Northern District of California, that Paul Hastings may and hereby does withdraw as counsel for Homejoy in this action.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.