SECOND JOINT CASE MANAGEMENT STATEMENT

VINCE CHHABRIA, District Judge.

JOINT CASE MANAGEMENT STATEMENT

The parties, by and through their counsel, jointly submit this Second Joint Case Management Statement in anticipation of the Case Management Conference scheduled for October 7, 2014, at 10:00 a.m.

I. SETTLEMENT REACHED AND SCHEDULING ISSUES

On September 16, 2014, the parties attended a mediation session with experienced mediator Mark Rudy. After the full day of negotiations, the parties reached a settlement in principle and executed a memorandum of understanding to that effect. The parties are currently working together to complete and execute a comprehensive settlement agreement. They will use their best efforts to finalize the settlement agreement no later than October 20, 2014 and to file promptly thereafter a motion for preliminary approval.

Because the mediation was successful, the parties request that the Court vacate any further litigation deadlines.

II. DISCLOSURE OF NON-PARTY INTERESTED ENTITIES OR PERSONS

Plaintiffs have retained Gregg Shavitz of the Shavitz Law Group, P.A. to co-counsel with Goldstein, Borgen Dardarian & Ho. They hereby disclose the Shavitz Law Group, P.A. as a non-party interested entity or person.

III. OTHER MATTERS

The parties respectfully request that the Court vacate the Case Management Conference set for October 7, 2014 so that they may focus their efforts on finalizing a settlement agreement. They also respectfully request that the Court set a further case management conference for November 18, 2014 at 10:00 a.m. or shortly thereafter when the Court is available so that the parties may report about their progress.