STIPULATION AND [PROPOSED] ORDER TO ALLOW LATE FILING OF CLAIM FORMS

JENNIFER A. DORSEY, District Judge.

WHEREAS, on April 19, 2016, the Court entered the Order Granting Preliminary Approval of Class Settlement ("Preliminary Approval Order") (ECF No. 430);

WHEREAS, the Preliminary Approval Order requires that Settlement Class Members must complete and return an executed Claim Form to the Claims Administrator before the expiration of the Notice Period in order to receive a Settlement Payment (id. at 6-7);

WHEREAS, the Notice Period expired on September 6, 2016, ninety days from the first mailing date postmarked on the first Notice of Class Action Settlement mailed by the Claims Administrator;

WHEREAS, the Claims Administrator received forty-four (44) Claim Forms from Settlement Class Members postmarked after September 6, 2016; and,

WHEREAS, Plaintiffs have requested to treat the late-mailed Claim Forms as timely submitted so that those Settlement Class Members may receive a Settlement Payment.

THEREFORE, Plaintiffs and Defendants, by and through their undersigned counsel, stipulate, subject to approval of the Court, to deem the Claim Forms postmarked after September 6, 2016, and received by the Claims Administrator no later than October 7, 2016, as timely filed and eligible to receive a Settlement Payment provided that Class Counsel file all Consent to Join forms for late-filed Claim Forms within ten court days after receipt of an order granting this stipulation.

IT IS SO STIPULATED.