[PROPOSED] STIPULATED ORDER RE SETTLEMENT COMPLIANCE AS MODIFIED HEREIN

JEFFREY S. WHITE, District Judge.

The parties to this matter, through their counsel of record, hereby stipulate to the following compliance schedule pursuant the finally approved Settlement Agreement and Release:

This Court entered the Final Approval Order on December 14, 2012. The Effective Date (Settlement Agreement and Release, hereafter "SAR" § 2.12) is calculated as one business day after the last day to appeal, i.e. 60 calendar days plus one business day. Based upon the date above on which the Final Order was entered, the Effective Date is February 13, 2013.

The Distribution Date (SAR § 2.13) is calculated as 15 calendar days after the Effective Date. Based upon the dates above, the Distribution Date is February 28, 2013.

The refund checks to be distributed to the eligible Settlement Class Members expire 120 calendar days after the Distribution Date (SAR § 5.02(a)), or 150 calendar days after the Distribution Date, if there is a dispute about the refund or the proper recipient of the refund (SAR § 5.02(b)). Based upon the dates above, the refund checks expire on July 28, 2013.

The Settlement Administrator, Kurtzman Carson Consultants, generally requires approximately two weeks after the refund checks expire to prepare a final accounting. Based upon the dates above, Kurtzman Carson Consultants shall file a Settlement Compliance Declaration, including a final accounting on or before August 12, 2013, and a Final Compliance hearing is scheduled on ____________, 2013 at 9.00 a.m. in Courtroom 11-19th Floor, in the U.S. District Court for the Northern District of California, located at 450 Golden Gate Ave, San Francisco, CA 94102

This stipulation may be executed in counterpart, and facsimile copies will be deemed as originals.

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED. Unless there is some dispute over compliance, the Court shall not set a hearing.