STIPULATION AND PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

EDWARD M. CHEN, District Judge.

Plaintiffs Marcus Betorina, Joseph Diaz, and Fred Bell ("Plaintiffs") and Defendant Randstad US, L.P. ("Randstad") (collectively "the Parties"), by and through their respective counsel, stipulate as follows:

1. On August 8, 2016, the Parties attended a mediation and reached an agreement to resolve this matter. They memorialized this agreement in a memorandum of understanding in which the Parties agreed to enter into a long-form settlement agreement.

2. Since then, the Parties have been working to finalize the long-form settlement agreement. The Parties have not yet finalized that settlement due to counsels' schedules and the Parties' desire to present the Court with a long-form agreement sufficient for preliminary approval, which includes a mechanism for class members to opt-into settlement of FLSA claim, which will be asserted in a proposed amended complaint, for settlement purposes only, prepared by Plaintiffs' counsel.

3. A case management conference ("CMC") in this case is currently scheduled for December 22, 2016. The Court continued the previous CMC to allow the Parties additional time to finish reducing their agreement to writing. Since the continuance, the Parties have been working together to finalize their agreement. The Parties are nearly finished with the agreement, but are not yet done. The Parties still believe that they will be able to reduce their agreement in writing.

4. Since the Parties need to finalize their agreement before Plaintiffs file the preliminary approval papers, which would be the main topic of discussion at the upcoming CMC, the Parties request that the Court continue the case management conference for thirty days or another date that the Court deems appropriate. The Parties believe that will allow them sufficient time to finalize the long-form settlement agreement so that a motion for preliminary approval can be filed.

IT IS SO STIPULATED.

ATTESTATION PURSUANT TO LOCAL RULE 5-1(i)(3)

I, Michael A. Wahlander, attest that concurrence in the filing of this stipulation has been obtained from the signatory, Kyle Nordrehaug, counsel for Plaintiff.

[PROPOSED ORDER]

Pursuant to the Parties' stipulation and good cause appearing therefore, the Court orders as follows:

The Case Management Conference currently scheduled for December 22, 2016 is VACATED. The Case Management Conference is reset for 2/2, 2017. A Joint Case Management Conference Statement is due on 1/26, 2017.

IT IS SO ORDERED.