CLASS ACTION

STIPULATION TO CONTINUE BRIEFING SCHEDULE ON FINAL APPROVAL OF CLASS CERTIFICATION AND CLASS ACTION SETTLEMENT AGREEMENT

JON S. TIGAR, District Judge.

WHEREAS, Plaintiff Maria Stewart filed her unopposed Motions for Class Certification and Preliminary Approval of Class Action Settlement on September 30, 2016;

WHEREAS, Said Motions were considered by this Court, without hearing, on February 6, 2017, and the Court set a final approval hearing for July 13, 2017, at 2:00 p.m. The Court further instructed Plaintiff to file her motion for final approval of the settlement, and application for attorneys' fees, costs, expenses, and service awards, no later than May 26, 2017.

WHEREAS, Plaintiff requests a two-week extension of the deadline for filing her approval motion, to June 9, 2017, and only if the Court deems necessary, a like extension of the date set for the final hearing on said motion. Plaintiff makes this request as the lawyer previously assigned to coordinating this action at her law firm, Kantor & Kantor, LLP, relocated and disassociated from the firm some months ago, and for reasons unknown, the May 26 deadline for filing said Motion was not calendared into the law firm's system. It was not until Monday, May 22, 2017, when defense counsel alerted plaintiff's counsel of the upcoming deadline, that plaintiff's counsel realized the error. The additional time is necessary in order for plaintiff's counsel to prepare and file the Motion. The parties further agree that they have no objection to keeping the July 13, 2017 hearing date for Motion on calendar, and that said date need only be extended should the Court deem it necessary or appropriate.

NOW THEREFORE, it is hereby stipulated and agreed, subject to the Court's approval, that the deadline for Plaintiff to file her Motion for Final Approval be continued from May 26, 2017 to June 9, 2017, and that the Final Hearing remain scheduled as set for July 13, 2017, at 2:00 p.m., or be continued if the Court deems necessary.

IT IS SO STIPULATED.

Filer's Attestation: Pursuant to Civil L.R. 5-1(i)(3) regarding signatures, Glenn R. Kantor hereby attests that concurrence in the filing of this document and its content has been obtained from all signatories listed.

[PROPOSED] ORDER

Pursuant to the parties' Stipulation, and good cause appearing, IT IS HEREBY ORDERED THAT:

• The deadline for Plaintiff to file her Motion for Final Approval is continued from May 26, 2017 to June 9, 2017, and that the Final Hearing [remain scheduled as set for July 13, 2017, at 2:00 p.m.], or [be continued to ________________.]

IT IS SO ORDERED.