STIPULATION AND ORDER CONTINUING PLAINTIFF'S DEADLINE TO FILE MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

WILLIAM H. ORRICK, District Judge.

STIPULATION

Plaintiff Erick Blandino ("Plaintiff") and Defendant MCM Construction, Inc. ("Defendant") (collectively "the Parties"), stipulate and agree as follows:

WHEREAS, on August 5, 2013, the parties stipulated and the Court entered an Order requiring Plaintiffs to file their Motion for Preliminary Approval of Class Action Settlement ("Motion for Preliminary Approval") by September 4, 2013, and set the hearing on the Motion for Preliminary Approval to take place on October 9, 2013 at 2:00 P.M.;

WHEREAS, on or about August 26, 2013, the parties finalized and entered into a long-form settlement agreement regarding the class action claims in the instant action. To this end, Plaintiff is in the process of drafting the Motion for Preliminary Approval and all accompanying documents but Plaintiff needs additional, updated information from Defendant in order to provide the Court with the required detail for its review of the Motion for Preliminary Approval; and

WHEREAS, the parties anticipate gathering the necessary updated information shortly. In order to allow the parties to finalize this process, Plaintiff is requesting a three-week extension of the current deadline to file the Motion for Preliminary Approval.

IT IS HEREBY STIPULATED that the deadline for Plaintiff to file the Motion for Preliminary Approval shall be continued from September 3, 2013 to September 25, 2013. The Case Management Conference and the hearing on the Motion for Preliminary Approval shall be continued from October 9, 2013 to October 30, 2013, or as soon thereafter as is convenient for the Court.

IT IS SO STIPULATED.

ORDER

The parties having so stipulated, and GOOD CAUSE APPEARING THEREFORE, IT IS HEREBY ORDERED that:

Plaintiff's deadline to file the Motion for Preliminary Approval shall be continued from September 4, 2013 to September 25, 2013.

The Case Management Conference and the hearing on the Motion for Preliminary Approval shall be continued from October 9, 2013 to October 30, 2013 at 2:00 p.m.