CLASS ACTION STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES PURSUANT TO LOCAL RULE 79-5

VINCE CHHABRIA, District Judge.

TO THE HONORABLE VINCE CHHABRIA, UNITED STATES DISTRICT JUDGE, PLAINTIFFS KAREN AND JEFFREY LUCIA, GAIL CAPLAN, PHILLIP R. CORVELLO, AND AMIRA JACKMON, THEIR COUNSEL OF RECORD, AND ALL OTHER INTERESTED PARTIES:

PLEASE TAKE NOTICE that pursuant to Civ. L.R. 6-1(b), 6-2, and 7-12, plaintiffs Karen Lucia, Jeffrey Lucia, Gail Caplan, Phillip R. Corvello, and Amira Jackmon ("plaintiffs") and defendant Wells Fargo Bank, N.A. ("Wells Fargo") (collectively, the "Parties"), by and through their respective counsel, stipulate and agree as follows:

WHEREAS, the Court entered a Scheduling Order in these cases on February 11, 2015 (Dckt. No. 118) ("Scheduling Order"); and

WHEREAS, the Scheduling Order requires plaintiffs to file their motion(s) for class certification by July 2, 2015; and

WHEREAS, plaintiffs may submit certain documents, testimony, or other information in support of their motions for class certification that have otherwise been designated as confidential by Wells Fargo or plaintiffs pursuant to the respective protective orders entered in the cases; and

WHEREAS, Local Rule 79-5 requires that plaintiffs file such documents, testimony, or other information in redacted form, and file accompanying administrative motion(s) to seal; and

WHEREAS, Local Rule 79-5 further requires that Wells Fargo submit a response (or responses) to the Court in support of sealing within 4 days of the filing of plaintiffs' administrative motion(s) to seal; and

WHEREAS, because plaintiffs' deadline for filing their motions for class certification falls directly before the federal Fourth of July holiday (on July 2, 2015), and in order to provide Wells Fargo with adequate time to evaluate the material filed by plaintiffs and prepare, as necessary, declarations in support of sealing, the Parties have conferred and agreed upon extending the deadline for plaintiffs to file their respective administrative motions to seal, if any, and the deadline for Wells Fargo to respond to same; and

WHEREAS, the Parties agree that no party will be prejudiced and no other deadlines will be affected by the extension.

IT IS HEREBY STIPULATED AND AGREED by the Parties as follows:

1. Plaintiffs' deadline to file their administrative motion(s) to seal, if any, pursuant to Local Rule 79-5 ("Administrative Motion(s)") is extended through and until July 8, 2015.

2. Wells Fargo's deadline to submit its response(s) to the Administrative Motion(s) is extended through and until July 22, 2015.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

PURSUANT TO STIPULATION, IT IS SO ORDERED.