Rodriguez v. Kraft Foods Group, Inc.

Filing 34

STIPULATION and ORDER RE: the Filing of Plaintiff's Motion for Preliminary Approval of Class Action Settlement signed by Magistrate Judge Erica P. Grosjean on 10/30/2015. (Martinez, A)

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DOUGLAS J. FARMER, Cal. Bar No. 139646
[e-mail]
CHRISTOPHER M. AHEARN, Cal. Bar No. 239089
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone:
415.442.4810
Facsimile:
415.442.4870

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Attorneys for Defendant
KRAFT FOODS GROUP, INC.

8 R. DUANE WESTRUP (State Bar No. 58610)
[e-mail]
9 CAT N. BULAON (State Bar No. 206612)
[e-mail]
10 WESTRUP & ASSOCIATES
444 West Ocean Boulevard, Suite 1614
11 Long Beach, California 90802-4524
Telephone:
562.432.2551
12 Facsimile:
562.435.4856
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Attorneys for Plaintiff
JOSE RODRIGUEZ

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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JOSE RODRIGUEZ, on behalf of himself and
all others similarly situated,

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Plaintiff,
vs.

Case No. 1:14-CV-01137-LJO-GSA
STIPULATION AND ORDER RE: THE
FILING OF PLAINTIFF'S MOTION FOR
PRELIMINARY APPROVAL OF CLASS
ACTION SETTLEMENT

KRAFT FOODS GROUP, INC., a Virginia
corporation; and DOES 1 through 100, inclusive,

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Defendant.
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Case No. 1:14-CV-01137-LJO-GSA
STIPULATION AND ORDER RE: THE FILING OF PLAINTIFF’S MOTION FOR PRELIMINARY APPROVAL

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Plaintiff Jose Rodriguez and Defendant Kraft Heinz Food Company, formerly Kraft Foods
Group, Inc. (collectively, the “Parties”) respectfully submit this Stipulation and Proposed Order
Re: Filing of Plaintiff’s Motion for Preliminary Approval. The Parties jointly and respectfully
request that the Court grant the relief sought by this Stipulation.

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WHEREAS, on October 22, 2015, the Court issued a minute order vacating all hearings and
other dates in this matter pending the filing of Plaintiff’s Motion for Preliminary Approval. [Dkt.
32]
WHEREAS, in the same order, the Court ordered that Plaintiff file his Motion for
Preliminary Approval on or before October 30, 2015.
WHEREAS, counsel for Plaintiff and Defendant are in the process of finalizing the
settlement agreement, expect to obtain signatures from their clients within the next few days, and
thus request that the Court extend the filing deadline from October 30, 2015, to November 4, 2015.
NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the Parties that
the current filing deadline in this matter should be continued, as follows:
(1) Plaintiff shall file his Motion for Preliminary Approval on or before November 4, 2015.
DATED: October 29, 2015

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OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By:

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DATED: October 29, 2015

/s/ Christopher M. Ahearn
DOUGLAS J. FARMER
CHRISTOPHER M. AHEARN
Attorneys for Defendant
KRAFT HEINZ FOOD COMPANY,
FORMERLY KRAFT FOODS GROUP,
INC.

WESTRUP & ASSOCIATES

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By: /s/ Cat N. Bulaon
CAT N. BULAON
Attorneys for Plaintiff
JOSE RODRIGUEZ

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Case No. 1:14-CV-01137-LJO-GSA
STIPULATION AND ORDER RE: THE FILING OF PLAINTIFF’S MOTION FOR PRELIMINARY APPROVAL

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ORDER

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Based on a review of the above stipulation and good cause appearing therein, the Court

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grants Plaintiff an extension to file his Motion for Preliminary Approval of Class Action

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Settlement. Plaintiff shall file his Motion for Preliminary Approval on or before November 4,

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2015.

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IT IS SO ORDERED.
Dated:

October 30, 2015

/s/
UNITED STATES MAGISTRATE JUDGE

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Case No. 1:14-CV-01137-LJO-GSA
STIPULATION AND ORDER RE: THE FILING OF PLAINTIFF’S MOTION FOR PRELIMINARY APPROVAL