STIPULATION VACATING FINAL APPROVAL HEARING DATE AND BRIEFING SCHEDULE

SAUNDRA BROWN ARMSTRONG, District Judge.

Plaintiffs Moises Zepeda, Michael Spear, Ronya Osman, Brian Pattee, Casey Ching, Denae Zamora, Michael Lavagna and Gary Miller (together, "Plaintiffs") and defendants PayPal, Inc. ("PayPal") and eBay Inc. (together, "Defendants"), through their undersigned counsel of record, stipulate as follows:

WHEREAS, on November 5, 2015, this Court entered an Order Granting Plaintiffs' Motion for Preliminary Approval of Amended Class Action Settlement Agreement (ECF No. 281) and, on January 28, 2016, entered an Order Setting Final Approval Schedule (the "Scheduling Order") (ECF No. 290);

WHEREAS, pursuant to the Scheduling Order, any responses to objections to the parties' Settlement Agreement (ECF No. 275-2) and any papers in support of final approval thereof must be filed on or before June 13, 2016, and the Final Approval Hearing is scheduled to take place on July 13, 2016 at 1:00 PM;

WHEREAS, the Scheduling Order provides, in pertinent part, that: "[t]he Final Approval Hearing may be postponed, adjourned, or continued by order of the Court without further notice to the Settlement Class";

WHEREAS, counsel for Defendants have advised counsel for Plaintiffs that PayPal recently learned that not all members of the Settlement Class were provided notice of the settlement and the Final Approval Hearing, and that Defendants are evaluating how to provide notice to those members of the Settlement Class that were not provided notice and require additional time to complete this evaluation and for the settlement administrator to provide notice;

WHEREAS, the parties hereby respectfully request that the Court vacate the July 13, 2016 date for the Final Approval Hearing and the June 13, 2016 date for submitting responses to objections and papers in support of final approval, so that the foregoing notice may be provided; and

WHEREAS, the parties will meet and confer and, as soon as practicable, propose a new schedule for the Final Approval Hearing and all related dates;

IT IS HEREBY STIPULATED, by and between Plaintiffs and Defendants, through their respective counsel of record, as follows:

1. The July 13, 2016 date for the Final Approval Hearing and the June 13, 2016 date for submitting responses to objections and papers in support of final approval shall be vacated; and

2. The parties shall meet and confer and, as soon as practicable, jointly propose a revised schedule for the Final Approval Hearing and all related dates.

[PROPOSED] ORDER

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.*