STIPULATION AND [PROPOSED] ORDER TO EXTEND CERTAIN DEADLINES

RICHARD SEEBORG, District Judge.

Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiffs John Bell, Jason Mears, Victor DeSimone, and Christina Lee ("Plaintiffs") and Defendant The Hershey Company ("Defendant") (collectively, "Parties"), through their respective counsel of record, and subject to the approval of the Court, hereby stipulate as follows:

1. WHEREAS, on June 26, 2014, the Court issued a Case Management Order setting certain deadlines (Dkt. No. 23);

2. WHEREAS, on October 16, 2014 and January 1, 2015, the Court issued Orders approving the Parties' stipulations to extend the mediation deadline and certain other deadlines in this matter (Dkt. Nos. 29 & 31);

3. WHEREAS, the Parties are actively engaged in discovery. The Parties have produced substantial documents, negotiated an ESI agreement, produced ESI pursuant to that agreement, Defendant has taken the depositions of all Plaintiffs, and Plaintiffs have scheduled the depositions of Defendant's witnesses; two of which will need to be taken after the close of the June 15, 2015 fact discovery deadline, and including one on June 17, 2015 in San Francisco;

4. WHEREAS, Plaintiffs disclosed an economic damages expert report on May 14, 2015 and, for the convenience of the parties and to save on expenses, Plaintiffs experts' are available for deposition on June 16, 2015;

5. WHEREAS, Defendant has a conflict with the case management conference that was rescheduled for June 25, 2015 and the parties have agreed to move the case management conference deadline to August 6, 2015;

6. THEREFORE, the Parties hereby agree and stipulate to the extension of these four deadlines as follows:

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

PURSUANT TO STIPULATION, IT IS SO ORDERED.