STIPULATION AND [PROPOSED] SCHEDULING ORDER (AS MODIFIED)

EDWARD J. DAVILA, District Judge.

WHEREAS, on April 8, 2016, the parties in the above-captioned Williamson and Kirby actions informed the Court that they had reached an agreement in principle, had executed a term sheet subject to full documentation, and had begun the process of preparing the final settlement agreement and related documentation;

WHEREAS, on May 26, 2016, the Court held a Status Conference in the Williamson and Kirby actions, during which counsel for the parties updated the Court that they had made significant progress towards finalizing the settlement papers, were continuing to work diligently on same, and anticipated finalizing the settlement papers and filing a motion for preliminary settlement approval within approximately one month;

WHEREAS, at the May 26, 2016 Status Conference, at the parties' suggestion, the Court directed the parties to confer regarding their availability and to submit by June 3, 2016 a proposed schedule regarding the anticipated motion for preliminary settlement approval. (Williamson Dkt. No. 88; Kirby Dkt. No. 59); and

WHEREAS, the parties have conferred and, based on the current status of the settlement papers and the availability of counsel and the Court, respectfully propose to the Court the following schedule:

NOW THEREFORE, ALL PARTIES, BY AND THROUGH THEIR UNDERSIGNED COUNSEL hereby stipulate and respectfully request that the Court set the following schedule regarding the anticipated motion for preliminary settlement approval:

IT IS SO STIPULATED.