STIPULATION TO EXTEND DEADLINE FOR CLASS NOTICE AND REQUEST TO AMEND POST-CLASS CERTIFICATION SCHEDULING ORDER

PEGGY A. LEEN, Magistrate Judge.

WHEREAS, on December 29, 2017, at the status hearing before the Court, the parties agreed to the form of a notice letter to be sent by mail to all class members and to continue meet and confer efforts to reach agreement on a plan for internet notice;

WHEREAS, also at the December 29, 2017 hearing, the parties agreed to set a January 5, 2018 deadline to send class notice to all class members, which was adopted by the Court (Docket No. 191);

WHEREAS, following the December 29, 2017 hearing, the parties have continued their efforts to reach agreement on a plan for internet notice and it appears an agreement has been reached pending receipt of additional information from Plaintiff's class notice administrator, Dahl Administration, including drafts of proposed banner ads, the full list of websites on which the internet notice would be posted, and the search terms that would trigger a banner ad for the class notice;

WHEREAS, the parties have agreed to submit for approval from the Court their agreed notice plan along with supporting materials to ensure that their proposed notice plan is sufficient to meet the requirements of Federal Rule of Civil Procedure 23(c)(2)(B);

WHEREAS, Dahl Administration has indicated that it will be able to provide a list of websites and search terms by early next week;

WHEREAS, Defendants have also discovered additional potential class members to be added to the class list, representing persons that were not originally assigned to be armed guards, but were later reclassified as armed guards, and have provided those additional individuals' contact information to Plaintiff;

WHEREAS, due to the parties' continued efforts to finalize an internet notice plan and list of recipients for mailing notice, and to receive approval of their notice plan from the Court, the parties wish to extend the deadline to provide notice to class members to allow completion of a joint notice plan for submission to the Court, so that notice can be provided to all class members at the same time and after the Court has approved the joint notice plan, and to request that the scheduling order be amended to reflect this new deadline;

WHEREAS, this request for an extension on the deadline to provide class notice will not 198871.1 impact any of the other deadlines ordered by the Court, including discovery deadlines;

NOW THEREFORE, the parties, by and through their counsel of record, hereby stipulate and agree to the following:

1. Plaintiff will submit to the Court the parties' joint proposed notice plan on January 10, 2018; in the event the parties cannot agree to a joint submission, Plaintiff will submit his proposed notice plan on January 10, 2018.

2. If the Court approves the notice plan, notice will be mailed two days after the Court's approval. The class notice will specify a 60-day opt-out period.

3. All other deadlines in this case remain unchanged.

IT IS SO ORDERED.