JOINT STIPULATION AND [PROPOSED] ORDER MODIFYING BRIEFING SCHEDULE AND NOTICED HEARING DATE RE: PLAINTIFF'S MOTION FOR ATTORNEYS' FEES AND NON-TAXABLE COSTS

EDWARD M. CHEN, District Judge.

Plaintiff Quiller Barnes and Defendant AT&T Pension Benefit Plan — Nonbargained Program (collectively referred to as the "Parties"), acting through their respective counsel of record, hereby stipulate as follows:

WHEREAS, on April 17, 2013, the Court entered final judgment on this case (D.E. #354);

WHEREAS, on April 30, 2013, Plaintiff filed PLAINTIFF'S MOTION FOR AWARD OF ATTORNEYS' FEES AND NON-TAXABLE COSTS (D.E. # 355) ("Motion") and noticed a hearing for June 6, 2013, such that Defendant's Opposition brief would be due on May 14, 2013 and Plaintiff's Reply brief would be due on May 21, 2013;

WHEREAS, Plaintiff's Motion is supported by several declarations and lengthy exhibits and Defendant requests additional time to review these declarations and exhibits; and Plaintiff requests additional time to respond to Defendant's opposition, including potentially engaging in further discussions with Plaintiff's counsel to narrow the issues in dispute;

WHEREAS, the Parties' counsel conferred regarding the briefing schedule on Plaintiff's Motion and agreed to request a change of the hearing date from June 6, 2013 to July 18, 2013 and to extend Defendant's Opposition deadline and Plaintiff's Reply deadline as set forth below;

IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES:

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.