STIPULATION AND [PROPOSED] ORDER REGARDING ORDER TO MEET AND CONFER AND SUBMIT JOINT DISCOVERY LETTER [DKT. NO. 139]

DONNA M. RYU, District Judge.

Pursuant to the Court's Order to Meet and Confer And Submit Joint Discovery Letter (Dkt. No. 139), Plaintiffs Crelencio Chavez, Carlos Alva, Andrew Owens, Joel Villasenor, and Jason McMillan ("Plaintiffs") and Defendant (collectively, the "Parties"), by and through their respective counsel of record, hereby timely respond to the Court's Order and submit the following stipulation regarding discovery in the above-captioned matters:

WHEREAS, on July 8 and July 11, 2014, the Parties met and conferred by telephone in compliance with the Court's Order and agreed to the following actions, which will occur on the following deadlines:

July 18, 2014: Plaintiffs will subpoena their bank records and debit and credit card statements for the respective time period(s) during which they were employed with Defendant and will serve Defendant with the records, marked confidential subject to a meet and confer between the Parties, immediately upon receipt.

July 18, 2014: Plaintiff Owens will provide Defendant with several possible non-weekend, non-holiday dates before August 18 on which he is available for deposition.

July 21, 2014: Each Plaintiff will provide Defendant with a signed Authorization for Release of Cell Phone Records to effectuate the release of telephone records. Any cell phone records produced in discovery will be marked confidential subject to a meet and confer between the Parties.

July 24, 2014: Each Plaintiff will serve substantive responses to Defendant's Request for Production of Documents and Interrogatories that comply with the Northern District's Civil Local Rules.

July 25, 2014: Each Plaintiff will produce any and all documents that are responsive to the Request for Production of Documents (except to the extent the Parties have reached a different agreement regarding the timing of production for cell phone records, bank records and credit and debit card statements, see supra);

August 4, 2014: Plaintiff McMillan will appear for deposition at the law office of Morgan Lewis in Los Angeles;

August 18, 2014: Plaintiffs Villasenor and Alva Plaintiffs will appear for a second day of deposition, if Defendant determines in good faith that a second day of deposition is necessary after reviewing and analyzing their respective production of responsive documents.

WHEREAS, on August 4, 2014, the Parties shall file a status report regarding Plaintiffs' compliance with the foregoing stipulations.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.