STIPULATION AND [PROPOSED] ORDER FOR APPROVAL OF SUPERSEDEAS BOND AND STAY OF EXECUTION AND ENFORCEMENT OF JUDGMENT PENDING APPEAL

JON S. TIGAR, District Judge.

Pursuant to Civil Local Rule 7-12, Plaintiff Michael Rodman, on behalf of himself and all others similarly situated ("Plaintiff"), and Defendant Safeway Inc. ("Safeway"), hereby stipulate and agree as follows:

WHEREAS, the Court entered judgment on November 30, 2015 (Dkt. No. 406).

WHEREAS, Safeway filed a Notice of Appeal to the United States Court of Appeals for the Ninth Circuit on December 4, 2015 (Dkt. No. 408).

WHEREAS, on December 11, 2015, pursuant to the parties' stipulation, the Court entered an Order for Extension of Stay of Execution and Enforcement of Judgment by which (1) any execution or enforcement of the judgment was stayed until and including January 5, 2016; and (2) a supersedeas bond in the amount of $42,000,000 was approved (Dkt. No. 412).

WHEREAS, on January 6, 2016, pursuant to the parties' stipulation, the Court entered an Order for Further Extension of Stay of Execution of Enforcement of Judgment by which any execution or enforcement of the judgment was stayed until and including January 12, 2016 (Dkt. No. 414).

WHEREAS, Safeway has obtained a supersedeas bond in the amount of $42,000,000, a copy of which is attached hereto as Exhibit A.

WHEREAS, the parties agree that any execution or enforcement of the judgment is stayed until fifteen days after issuance of the mandate by the United States Court of Appeals for the Ninth Circuit.

ORDER

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that any execution or enforcement of the judgment is stayed until fifteen days after issuance of the mandate by the United States Court of Appeals for the Ninth Circuit.