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Danielle Warren, and All Others Similarly Situated v. Paychex

April 7, 2011

DANIELLE WARREN, AND ALL OTHERS SIMILARLY SITUATED,
PLAINTIFF,
v.
PAYCHEX, INC.
DEFENDANT.



STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE FROM APRIL 8, 2011 TO APRIL 22, 2011.

Plaintiff Danielle Warren ("Plaintiff") and Defendant Paychex, Inc. ("Defendant") 2(collectively, the "Parties"), by and through their respective counsel of record, stipulate and 3 agree as follows:

WHEREAS, the Court set a Case Management Conference for April 8, 2011 at 11:30 5 a.m.; 6

WHEREAS, the parties, after mediation on January 12, 2011, have reached a proposed settlement of the action;

WHEREAS, the settlement still needs to be formalized by a Joint Stipulation and 9 subsequently approved by the Court, and said actions will not be complete by April 8, 2011; 10

WHEREAS, the parties respectfully request that the conference be delayed to have 11 sufficient time to finalize the settlement or seek judicial assistance; 12

Dated: April 6, 2011 RUDY EXELROD ZIEFF & LOWE LLP By: /s/ Steven G. Zieff STEVEN G. ZIEFF DAVID A. LOWE JOHN T. MULLAN Dated: April 6, 2011 NELSON LAW GROUP 20 21 By: /s/ Robert S. Nelson ROBERT S. NELSON Attorneys for Danielle Warren and all others similarly situated Dated: April 6, 2011 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. By: /s/ Jack S. Sholkoff Jack S. Sholkoff Beth A. Gunn Attorneys for Defendant PAYCHEX, INC.

The parties hereby stipulate and agree that the Court should continue the Case 13Management Conference set for April 22, 2011 at 1:30 p.m.

IT IS SO ORDERED U A

I N

N C. Spero

O Judge Joseph O

R

R ...


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