STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRETRIAL DEADLINES

VINCE CHHABRIA, District Judge.

Pursuant to Civil Local Rule 7-12, Plaintiffs Dana Rhinerson and Aidin Moradi ("Plaintiffs") and Defendant Van's International Foods ("Defendant") (collectively, "the Parties"), by and through their counsel of record, hereby stipulate and agree as follows:

WHEREAS, the Court has previously ordered the following dates and pretrial deadlines:

WHEREAS, the Parties have exchanged and responded to initial rounds of written discovery and continue to meet and confer in order to informally resolve any discovery disputes.

WHEREAS, the Parties began the task of electronic discovery on October 14, 2014, and are currently working to finalize an electronic discovery protocol. Defendant has retained an electronic discovery provider, Advanced Discovery, and the Parties expect that electronic discovery will commence in earnest within the next sixty days.

WHEREAS, since the inception of this case, Defendant has undergone two separate change of control transactions which have resulted in significant changes in management and have unintentionally contributed to delays in the discovery process.

WHEREAS, in addition to making strides toward completing discovery, the parties have also focused on scheduling a mediation. The Parties have selected Bruce A. Friedman as a mediator and are currently attempting to schedule a mediation date prior to March 25, 2015.

WHEREAS, although the Parties have been diligently working to complete discovery, the parties need additional time to complete discovery prior to the filing of Plaintiff's Motion for Class Certification and thus agree that a continuance of the pretrial deadlines of five months is necessary to complete discovery.

WHEREAS, the Parties further agree that this stipulation will not alter or affect any other dates and pretrial deadlines set by the Court other than those set forth supra. Moreover, the parties agree that this stipulation does not act to re-open or affect any previously-expired deadline.

NOW, THEREFORE, the Parties stipulate and agree to the following discovery deadlines, briefing schedule and hearing date regarding Plaintiffs' Motion for Class Certification:

1. These stipulated date and deadline changes will not change or alter, or serve as the basis to change or alter, any other deadlines currently set by the Court other than those set forth supra. Moreover, this stipulation will not act to reopen any previously-elapsed dates or deadlines.

IT IS SO STIPULATED.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.