Campbell v. PriceWaterhouse Coopers, LLP

Filing 646

STIPULATION and ORDER RE: MATTERS TO BE ADDRESSED AT 1/29/15 STATUS CONFERENCE signed by District Judge Troy L. Nunley on 1/20/15 645 . (Meuleman, A)

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WILLIAM A. KERSHAW (SBN 057486)
LYLE W. COOK (SBN 148914)
STUART C. TALLEY (SBN 180374)
KERSHAW, CUTTER & RATINOFF, LLP
401 Watt Avenue
Sacramento, CA 95864
Telephone: [phone]
Facsimile: [phone]
JAMES P. ULWICK (Admitted Pro Hac Vice)
JEAN E. LEWIS (SBN 148717)
KRAMON & GRAHAM, P.A.
One South Street, Suite 2600
Baltimore, Maryland 21202
Telephone: [phone]
Facsimile: [phone]

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JULIAN W. POON, SBN 219843
ALEXANDER K. MIRCHEFF, SBN 245074
GIBSON, DUNN & CRUTCHER LLP
333 South Grand Avenue
Los Angeles, California 90071-3197
Telephone: (2l3) 229-7000
Facsimile: (2l3) 229-7520

Attorneys for Plaintiffs

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DANIEL J. THOMASCH
(Admitted Pro Hac Vice)
LAUREN J. ELLIOT
(Admitted Pro Hac Vice)
GIBSON DUNN & CRUTCHER LLP
200 Park Avenue
New York, New York 10166-0193
Telephone: [phone]
Facsimile: [phone]

NORMAN C. HILE, SBN 57299
JULIE A. TOTTEN, SBN166470
ANDREA L. BROWN, SBN 237629
ORRICK, HERRINGTON & SUTCLIFFE LLP
400 Capitol Mall, Suite 3000
Sacramento, California 95814-4497
Telephone: [phone]
Facsimile: [phone]

MICHELE L. MARYOTT, SBN 191993
GIBSON, DUNN & CRUTCHER LLP
3161 Michelson Drive
Irvine, California 92612-4412
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
PRICEWATERHOUSECOOPERS LLP

Attorneys for Defendant
PRICEWATERHOUSECOOPERS LLP

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JASON CAMPBELL and SARAH
SOBEK, individually, and on behalf of all
other similarly situated current and former
employees of PricewaterhouseCoopers,
LLP,

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Plaintiffs,

Case No.: 06-CV-02376-TLN-AC
STIPULATION AND ORDER RE
MATTERS TO BE ADDRESSED AT
JANUARY 29, 2015 STATUS
CONFERENCE

vs.

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PRICEWATERHOUSECOOPERS, LLP,
a Limited Liability Partnership,

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Date: January 29, 2015
Time: 2:00 p.m.
Courtroom 2, 15th Floor
Assigned to Judge Troy L. Nunley

Defendant.

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STIPULATION AND ORDER RE MATTERS TO BE ADDRESSED AT STATUS CONFERENCE

Plaintiffs

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Jason

Campbell

and

Sarah

Sobek

(“Plaintiffs”)

and

Defendant

PricewaterhouseCoopers LLP (“PwC” or “Defendant”) hereby stipulate to the following:

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WHEREAS, Magistrate Judge Kendall J. Newman entered a Minute Order on January 7,

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2015 vacating existing dates in this matter and setting a status conference before Honorable Troy

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L. Nunley on January 29, 2015 (“Minute Order”) (Dkt. No. 641);

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WHEREAS, the Minute Order directed the parties to file the necessary documents and a

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stipulation addressing the matters to be addressed at the status conference, as well as a schedule

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for proceedings following the status conference;

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WHEREAS, on January 14, 2015, Plaintiffs filed an Unopposed Motion for Preliminary

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Approval of Class Action Settlement and a [Proposed] Order Granting Preliminary Approval of

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Class Action Settlement, which attaches the parties’ Settlement Agreement and Release as an

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exhibit;

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WHEREAS, pursuant to 28 U.S.C. Section 1715(b)(1), Defendant is required to serve

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notice of the proposed settlement upon the appropriate State official of each State in which a class

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member resides and the appropriate Federal official (“CAFA Notice”) by January 24, 2015; and

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WHEREAS, pursuant to 28 U.S.C. Section 1715(d), an order giving final approval of the

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proposed Settlement of this action may not be issued earlier than 90 days after service of the

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CAFA Notice, i.e., not earlier than April 24, 2015.
IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs and Defendant,

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through their respective undersigned counsel, that:
1.

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The January 29, 2015 status conference be converted into a hearing on Plaintiffs’
Unopposed Motion for Preliminary Approval of Class Action Settlement;

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2.

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In the event that this Court grants Preliminary Approval of the Settlement,

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Plaintiffs will file their Motion for Fees and Costs by February 25, 2015, and

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Plaintiffs will file their Motion for Final Approval by March 20, 2015, both of

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which will be addressed at the Final Approval Hearing.

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///

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-1STIPULATION RE MATTERS TO BE ADDRESSED AT STATUS CONFERENCE

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3.

The Court will set a date for the Final Approval Hearing at the January 29, 2015
hearing.

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Dated: January 15, 2015

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KERSHAW, CUTTER, & RATINOFF, LLP

By:

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/s/ William A. Kershaw
William A. Kershaw
Attorneys for Plaintiffs

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Dated: January 15, 2015

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DANIEL J. THOMASCH
LAUREN J. ELLIOT
MICHELE MARYOTT
JULIANPOON
Gibson, Dunn & Crutcher LLP

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NORMAN C. HILE
JULIE A. TOTTEN
ANDREA L. BROWN
Orrick, Herrington & Sutcliffe LLP

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By:

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/s/ Daniel J. Thomasch
DANIEL J. THOMASCH
Attorneys for Defendant
PRICEWATERHOUSECOOPERS LLP

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IT IS SO ORDERED.

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Dated: January 20, 2015

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Troy L. Nunley
United States District Judge

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-2STIPULATION RE MATTERS TO BE ADDRESSED AT STATUS CONFERENCE