STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING AND RELATED DEADLINES FOR PLAINTIFFS' MOTION FOR CLASS CERTIFICATION

JEFFREY S. WHITE, District Judge.

TO THE COURT:

By and through their counsel of record, Plaintiffs Justin Aston and Steven E. De Borba ("Plaintiffs") and United Parcel Service, Inc. and UPS Ground Freight, Inc. ("Defendants") (collectively "the Parties") hereby submit the following stipulation:

August 19, 2016 at 9:00 a.m.;

WHEREAS, on March 11, 2016, the Parties attended a full-day mediation with mediator David Rotman in San Francisco, California.

WHEREAS, upon the conclusion of the mediation, the Parties agreed to conduct a second mediation with Mr. Rotman, which is presently scheduled for May 31, 2016;

WHEREAS, the Parties agree that in the event that they are unable to settle this case at the mediation, additional time will be needed to complete discovery, including the taking of multiple depositions, related to Plaintiffs' class action claims prior to filing the motion for class certification and opposition thereto;

THEREFORE, the Parties respectfully request that the Court continue the hearing and the filing deadlines for Plaintiffs' Motion for Class Certification be at least 30 days from August 19, 2016 to September 23, 2016, or as soon thereafter as convenient for the Court, to allow the Parties time to complete pre-class certification discovery fully and thoroughly in the event that the Parties are unable to reach a settlement at the mediation on May 31, 2016.

ORDER

The Court, having reviewed the foregoing Stipulation and good cause appearing therefore, orders as follows:

The hearing on Plaintiffs' Motion for Class Certification currently scheduled for August 19, 2016 is continued to September 23, 2016. The filing deadlines will be pursuant to code.

IT IS SO ORDERED.