JOINT STIPULATION AND [PROPOSED] ORDER TO SHORTEN TIME ON HEARING FOR PLAINTIFFS' UNOPPOSED MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFFS DEBRA SLEDGE, JOAN SLEDGE, AND KIM SLEDGE ALLEN

RICHARD SEEBORG, District Judge.

Plaintiffs and Defendant hereby enter the following Joint Stipulation and [Proposed] Order to Shorten Time on the Hearing for Plaintiffs' Unopposed Motion for Leave to Withdraw as Counsel for Plaintiffs Debra Sledge, Joan Sledge, and Kim Sledge Allen ("Motion to Withdraw"):

WHEREAS, Plaintiffs filed their unopposed Motion to Withdraw on December 5, — with a noticed hearing date of January 9, 2014. (Dkt. 82);

WHEREAS, the parties do not expect any opposition or reply to the Motion to Withdraw;

WHEREAS, on August 31, 2012, this Court granted a stay of the proceedings to allow the parties to participate in settlement discussions, which stay has been extended through December 12, —;

WHEREAS, over the course of this time, the parties have diligently participated in settlement negotiations, and while they have not reached a settlement at this juncture, the negotiations are constructive and progress has been made. All parties are committed to continuing the settlement discussions at this time;

WHEREAS, to the extent settlement can be reached, the parties would hope to obtain an order granting preliminary approval of any settlement by February 1, 2014, so that notice of the settlement could be disseminated to class members with Defendant's next mailing cycle of royalty statements;

WHEREAS, to the extent settlement can be reached, failure to send notice in that mailing cycle could result in a delay of six months or more in providing notice to the class and cause further delay;

WHEREAS, the Motion to Withdraw must be addressed by the Court before settlement can be reached or any motion for preliminary approval filed;

WHEREAS, this request for an order shortening time will not have a negative effect on the schedule for the case since this Court has stayed proceedings to allow the parties to participate in settlement negotiations;

WHEREAS, there is already a Case Management Conference scheduled in this case for December 12, 2013, at 10:00 am.

PURSUANT TO CIVIL LOCAL RULE 6-2, THE PARTIES HEREBY STIPULATE that the hearing, if any, on Plaintiffs' unopposed Motion to Withdraw shall be heard on December 12, —, at 1:30 p.m.

IT IS SO STIPULATED.

PURSUANT TO STIPULATION, IT IS SO ORDERED.