JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE FOR JOINT MOTION TO TRANSFER

EDWARD M. CHEN, District Judge.

STIPULATION

WHEREAS, on March 9, 2016, the parties filed a Notice of Settlement and Request to Vacate all Dates on Calendar (ECF No. 124), informing the Court that they have reached an agreement in principle to resolve the claims of the Plaintiffs and the putative class as part of a settlement of the following other cases: Devries v. Morgan Stanley & Co., LLC, No. 12 Civ. 81223 (S.D. Fla); Hix v. Morgan Stanley & Co., LLC, No. 15 Civ. 1157 (D. Md.); and Johnson v. Morgan Stanley & Co., LLC, No. 15 Civ. 4856 (S.D.N.Y.) ("Notice of Settlement");

WHEREAS, the Notice of Settlement informed that Court that the terms of the settlement, agreed to by the parties, call for the settlement to be memorialized in a comprehensive settlement stipulation and for the parties to move to transfer this case (as well as the Hix and Johnson actions) to the Southern District of Florida to be joined with Devries before Judge Marra for purposes of seeking approval of the settlement;

WHEREAS, the Notice of Settlement stated that the parties would finalize a formal settlement stipulation and submit a joint motion to transfer no later than April 11, 2016;

WHEREAS, on March 15, 2016, the Court stamped the last page of the Notice of Settlement, "it is so ordered as modified" and inserted the following language: IT IS SO ORDERED that the further CMC is reset from 3/23/16 to 5/5/16 at 10:30 a.m. An updated joint CMC statement shall be filed by 4/28/16." (ECF No. 125);

WHEREAS, on April 11, 2016, the parties filed their first Joint Stipulation and Proposed Order to Continue Deadline for Joint Motion to Transfer and Case Management Conference to afford the parties additional time to complete negotiations on their settlement stipulation and finalize same along with other required submissions, including their joint motion to transfer. (ECF No. 126);

WHEREAS, on April 12, 2016, the Court entered the parties' Joint Stipulation and Proposed Order to Continue Deadline for Joint Motion to Transfer and Case Management Conference setting the deadline for the parties to file their joint motion to transfer to May 11, 2016 and continuing the CMC to June 30, 2016. (ECF No. 127);

WHEREAS, the parties have diligently been working to prepare the settlement stipulation and other required submissions, including the joint motion to transfer in this matter as well as in the Hix and Johnson matters;

WHEREAS, given the ongoing efforts to negotiate the settlement stipulation in these matters, the parties require additional time to submit a joint motion to transfer;

WHEREAS, at this time the parties intend to complete and submit their joint motion to transfer in advance of the June 30, 2016 CMC and thus no other deadlines will be affected by this Stipulation.

ACCORDINGLY, THE PARTIES HEREBY STIPULATE AND AGREE to continue the deadline to file a joint motion to transfer to June 10, 2016.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.