STIPULATION AND [PROPOSED] ORDER MODIFYING DECEMBER 11, 2014 CASE MANAGEMENT MINUTE ORDER

EDWARD M. CHEN, District Judge.

The parties, through their respective counsel, hereby make the following stipulations and request.

WHEREAS, on December 11, 2014 this Court entered a Case Management Minute Order in which the parties were ordered to complete mediation by April 30, 2015 and Plaintiffs were allowed to take three depositions and Defendant ESA Management ("ESA") were allowed to take seven depositions prior to mediation.

WHEREAS, the parties have worked diligently to complete a first round of written discovery in preparation for the pre-mediation depositions;

WHEREAS ESA has completed three of the seven depositions permitted prior to the mediation and have scheduled the remaining four to take place by the end of March 2015.

WHEREAS Plaintiffs are anticipating deposing two defense witnesses in April 2015, after they receive further production of documents from ESA.

WHEREAS, the parties have had difficulties scheduling a mediation to take place on or before April 30, 2015 due to a variety of circumstances, including mediator availability, counsel travel plans, arrangements to have one plaintiff return from out-of-state to sit for his deposition in San Francisco, and coordinating the availability of the parties (including all seven plaintiffs, six of whom are former employees of ESA and one who is expecting a baby in mid-April).

WHEREAS, after seeking appropriate dates from three different mediators, the parties have now scheduled mediation with David Rotman on May 12, 2015.

Based upon these stipulations, the parties respectfully request the Court modify its previous Case Management Minute Order to allow the parties until May 26, 2015 to complete mediation in this matter.

The parties also respectfully request that the Court reschedule the Further Case Management Conference, currently on calendar for May 14, 2015, to a date after the scheduled mediation.

All other dates, deadlines and obligations set forth in the Court's December 11, 2014 Case Management Minute Order shall remain unchanged.

IT IS HEREBY ORDERED that the Court's December 11, 2014 Case Management Minute Order is modified as follows:

1. The parties are to complete private mediation by May 26, 2015.

2. The current Further Case Management Conference, scheduled for May 14, 2015, is hereby vacated and rescheduled to June 18, 2015. at 10:30 a.m. Updated Joint CMC statement due June 11. 2015.

3. All other dates, deadlines and obligation set forth in the Court's December 11, 2014 Case Management Minute Order shall remain unchanged.

IT IS SO ORDERED.