STIPULATION AND [PROPOSED] ORDER CONTINUING DATE TO FILE MOTION FOR PRELIMINARY APPROVAL

          VINCE CHHABRIA, District Judge.

         Pursuant to the following stipulation Plaintiff Barry Jekowsky and Defendant BMW of North America, LLC, by and through their respective undersigned counsel of record, hereby request that the Court grant a two-week continuance of Plaintiff's deadline to file his Preliminary Approval of Class Settlement Motion. Pursuant to the Court's November 18, 2014 Order, Plaintiff was to file the Preliminary Approval of Class Settlement Motion by January 30, 2015.

         STIPULATION

         Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Barry Jekowsky and Defendant BMW of North America, LLC, stipulate and request as follows:

         WHEREAS, on November 18, 2015 the parties appeared at a telephonic Case Management Conference and informed the Court that the case had settled after a full day mediation on October 20, 2014 with the Honorable Edward Infante at JAMS;

         WHEREAS, pursuant to the Court's November 18, 2014 Order Plaintiff was to file the Motion for Preliminary Approval of Class Settlement by January 30, 2015 and the hearing on the Motion for Preliminary Approval of Class Settlement was scheduled for March 12, 2015;

         WHEREAS, since the hearing on November 18, 2014, the parties have exchanged five (5) drafts of the Settlement Agreement and Release along with exhibits which include the proposed class notice and proposed claim form;

         WHEREAS, the parties are in the process of finalizing the Settlement Agreement and Release and exhibits and a result of this process, have identified certain terms in their proposed agreement that require further clarification and as a result, the parties do not currently have a Settlement Agreement and Release ready for signature;

         WHEREAS, the parties believe they will have a Settlement Agreement and Release ready for signature by February 6, 2015;

         WHEREAS, Plaintiff will be ready to file his Motion for Preliminary Approval of Class Settlement on or before February 13, 2015;

         NOW, THEREFORE, IT IS HEREBY STIPULATED AND REQUESTED that the Court continue the January 30, 2015 date for filing of the Motion for Preliminary Approval of Class Settlement up to and including February 13, 2015. Because there will be no opposition to the Preliminary Approval of Class Settlement Motion, the parties request that the Court retain the March 12, 2015 hearing date for Preliminary Approval of Class Settlement Motion.

         E-FILING ATTESTATION

         By his signature below, counsel for Plaintiff Jekowsky attests that counsel for all parties whose electronic signatures appear below have concurred in the filing of this Stipulation.

          ORDER

         PURSUANT TO THE STIPULATION, IT IS SO ORDERED.