STIPULATION AND ORDER RE SECOND MOTION FOR CONDITIONAL CERTIFICATION STIPULATION AND [PROPOSED] ORDER RE SECOND MOTION FOR CONDITIONAL CERTIFICATION
WHEREAS, on April 22, 2009, the Court issued an Order directing Plaintiffs Samuel Brandon Kress, Lac Ahn Le, Jason Patterson, Lauren San Mateo, James Stekelberg, Jeffrey Laberge, Willow Markham, Dana Blindbury, Jesse Kenny, Kelly C. Jones, and Antoine Powell (collectively, Plaintiffs) to file, inter alia, their second Fair Labor Standards Act ("FLSA") collective certification motion as to a putative nationwide class of Associates and Senior Associates in Defendant PricewaterhouseCoopers LLP's ("PwC") Advisory and Tax lines of service and Senior Associates in PwC's Assurance line of service by May 14, 2010 ("Second Motion for Conditional Certification");
WHEREAS, the parties are negotiating the terms of a potential stipulated consent to conditional certification as to some of the groups of employees at issue in Plaintiffs' Second Motion for Conditional Certification;
WHEREAS, the parties need additional time to consider and negotiate the stipulation;
WHEREAS, the stipulation being negotiated, if finalized, will impact the scope of Plaintiffs' Second Motion for Conditional Certification;
WHEREAS, the parties have met and conferred and agree to extend the deadline for Plaintiffs to file their Second Motion for Conditional Certification by two weeks to May 28, 2010;
ACCORDINGLY, IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs and PwC, by and through their respective undersigned counsel, that:
1. Plaintiffs' Second Motion for Conditional Certification may be filed on or before May 28, 2010;
2. PwC's opposition brief shall be filed 45 days from the date Plaintiffs file their Second Motion for Conditional Collective Certification, and Plaintiffs' reply brief shall be filed 30 days thereafter;
3. All other dates set forth in the Court's April 22, 2009 order shall remain in effect.
PURSUANT TO STIPULATION, IT IS ...