STIPULATION AND [PROPOSED] ORDER REGARDING (1) EXTENSION OF BRIEFING DEADLINES RE MOTION FOR ATTORNEYS' FEES AND COSTS AND (2) HEARING DATE ON MOTION FOR ATTORNEYS' FEES

EDWARD M. CHEN, District Judge.

STIPULATION

The Plaintiffs have filed a motion for preliminary approval of a class action settlement and a motion for attorneys' fees.

The Court has set a hearing date on the motion for preliminary approval for February 6, 2014.

The Court has set a hearing date on the motion for attorneys' fees for March 13, 2014, with Costco's opposition due on January 24, 2014 and Plaintiffs' reply due on February 24, 2014.

The Parties submit that the briefing schedule and the hearing on the motion for attorneys' fees should be moved for two reasons. First, the Parties have been discussing information that may lead Costco not to oppose the motion. Additional time will allow those discussions to be completed. Second, the current hearing date of March 13, 2014, will come before class members will have the full period notice period to lodge objections to the fee request, as any notice to the class will not occur until sometime after the February 6 hearing date on the motion for preliminary approval. Thus, a modest relaxation of the current briefing and hearing dates may avoid unnecessary briefing and permit for a more streamlined hearing at a time when the Court will have more information available to it.

Therefore, Counsel for Plaintiffs and the Certified Classes and Defendant Costco Wholesale Corporation stipulate as follows:

IT IS SO STIPULATED.

The Court orders as follows:

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED: