STIPULATION AND [PROPOSED] ORDER RE DEADLINE TO SUBMIT SETTLEMENT AGREEMENT AND HEARING DATES FOR PRELIMINARY APPROVAL

VINCE CHHABRIA, District Judge.

WHEREAS, Plaintiff and Defendant Source Refrigeration & HVAC, Inc. ("Source") (collectively, the "Parties") jointly submit this Stipulation and Proposed Order requesting that the Court continue the Thursday, February 5, 2015 deadline for the Parties to present the settlement agreement and motion for preliminary approval to today;

WHEREAS, the Parties also request that the Court set Thursday, February 26, 2015 as the deadline for any opposition to the motion for preliminary approval (which is eight days after filing as opposed to the usual 14), Saturday, February 28, 2015 as the deadline for any reply brief (which is two days later as opposed to the usual seven), and Monday, March 9, 2015 at 1:00 p.m. as the hearing date and time (as currently scheduled) (which is nine days after the reply brief deadline as opposed to the usual 14);

WHEREAS, the Parties believe that this schedule affords time for a ruling on preliminary approval, given that all Parties together jointly support the motion and settlement, and therefore there is no party who will oppose the motion, making a reply unnecessary.

WHEREAS, if any individual or entity (including an absent class member) were to oppose this motion, that individual or entity would have to move to intervene, which would necessitate further briefing and possibly a delay in the hearing;

WHEREAS, if the Court prefers a slower schedule, the Parties jointly propose Thursday, March 12, 2015, at 10:00 a.m. (or any other time the Court wishes);

WHEREAS, the Parties are also available on Thursday, March 19, 2015;

THEREFORE, the Parties respectfully request that the Court order that:

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED that:

IT IS SO ORDERED.