STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF DEADLINES

WILLIAM B. SHUBB, District Judge.

Plaintiff, RYAN GUINN ("Plaintiff"), and Defendant, SUGAR TRANSPORT OF THE NORTHWEST, INC. ("Sugar Transport"), (hereafter, when referenced in a collective manner, Plaintiff and Sugar Transport will be referred as "the Parties"), by and through their respective attorneys of record, hereby stipulate and agree as follows:

WHEREAS, on June 17, 2016, the Court entered a scheduling order, titled "Status (Pretrial Scheduling) Order" Document 22;

WHEREAS, on February 24, 2017, the Court entered a stipulated order, titled "Stipulation and Order Extending Scheduling Order," Document 61, revising the Scheduling Order in this Case;

WHEREAS, on May 17, 2017, the Court entered a stipulated order, titled "Stipulation and Order Further Amending Scheduling Order and Extending Scheduling Date for Filing Motion for Class Certification," Document 69, further revising the scheduling order in this Case;

WHEREAS, on November 30, 2017, the Court entered a stipulated order, titled "Stipulation and Order Amending Scheduling Order" Document 77, further revising the scheduling order in this Case setting forth certain dates and deadlines in this action;

WHEREAS on May 23, 2018, the Court entered a stipulated order, titled "Stipulation and Order for Extension of Deadlines" Document 96, further revising the scheduling order in this Case setting forth certain dates and deadlines in this action;

WHEREAS, on July 9, 2018, the Court heard a joint motion filed by Plaintiff and Defendants Bronco Wine Company and Classic Wines of California (collectively as "Bronco") to approve the settlement reached by and between them;

WHEREAS, on or about July 13, 2018, the Court granted the motion to approve the settlement, in part, and ordered Bronco dismissed from this Case with prejudice;

WHEREAS, on or about August 10, 2018, the Parties and Bronco agreed to a broad outline of a settlement but have yet to finalize an agreement memorializing all of the material terms of the settlement. Through this proposed agreement, the Parties and Bronco not only intend to memorialize the terms upon which Plaintiff and Sugar Transport have agreed to resolve the remaining issues in this Case and also set forth the terms upon which they, and Bronco, have agreed to resolve six related state court actions, all of which were brought against Sugar Transport and Bronco.

WHEREAS, though the Parties are working diligently to finalize the agreement, it has not yet occurred, though they reasonably expect each and all of the terms thereof will be agreed to shortly and, thereafter, will be placed into the agreement;

WHEREAS, once the material terms of the settlement agreement are agreed to and the agreement is then signed, because some of Plaintiff's claims are subject to the Fair Labor Standards Act, the attorneys for Plaintiff and Sugar Transport reasonably believe they will have to obtain approval of the proposed settlement from this Court;

WHEREAS, given that the Parties need more time to finalize the settlement agreement and then to obtain this Court's approval for that agreement, the Parties believe it is appropriate to move: (1) the hearing date for the currently pending motion for summary judgment; and (2) the Pre-Trial conference date. Any further litigation of this matter will only increase the costs of litigation for the Parties and burden on this Court.

THEREFORE, the Parties hereby stipulate and agree to move the hearing date on the motion for summary judgment and modify the "Stipulation and Order Amending Scheduling Order," Document 96, as follows:

STIPULATION

1) The hearing date for Sugar Transport's Motion for Summary Judgment or in the Alternative Summary Adjudication shall be moved from September 17, 2018 at 1:30 p.m. to October 29, 2018 at 1:30 p.m. The briefing schedule will follow the new hearing date; and

2) The Final Pretrial Conference shall be continued from to November 19, 2018 at 1:30 p.m. to December 3, 2018 at 1:30 p.m.

IT IS SO STIPULATED.

ORDER

GOOD CAUSE APPEARING, it is hereby ORDERED that:

1) The hearing date for Sugar Transport's Motion for Summary Judgment or in the Alternative Summary Adjudication shall be moved from September 17, 2018 at 1:30 p.m. to October 29, 2018 at 1:30 p.m. The briefing schedule will follow the new hearing date; and

2) The Final Pretrial Conference shall be continued from to November 19, 2018 at 1:30 p.m. to December 3, 2018 at 1:30 p.m.

IT IS SO ORDERED.