Campbell v. PriceWaterhouse Coopers, LLP

Filing 650

STIPULATION and ORDER RE: ADDENDUM TO SETTLEMENT AGREEMENT AND RELEASE signed by District Judge Troy L. Nunley on 2/9/2015. (Zignago, K.)

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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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Case No.: 06-CV-02376-TLN-AC
STIPULATION AND ORDER RE:
ADDENDUM TO SETTLEMENT
AGREEMENT AND RELEASE

Plaintiffs,
vs.

Courtroom 2, 15th Floor
Assigned to Judge Troy L. Nunley

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PRICEWATERHOUSECOOPERS, LLP,
a Limited Liability Partnership,

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Defendant.

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STIPULATION RE: ADDENDUM TO SETTLEMENT AGREEMENT AND RELEASE

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, on January 14, 2015, the Parties entered into the Settlement Agreement and

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Release in the above-referenced action, which received Preliminary Approval by the Court by

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Order dated January 30, 2015 (“Settlement Agreement and Release”);

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WHEREAS, Plaintiffs have requested an amendment of the Settlement Agreement and

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Release in order to ensure that each Settlement Class Member will be entitled to receive a

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minimum settlement payment of $100 from the Gross Settlement Payment;

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WHEREAS, any funds necessary to make such payments would be withheld from the Fee

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Award authorized by the Court to be paid to Class Counsel by the Settlement Administrator from

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the Gross Settlement Payment;

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WHEREAS, the Parties desire to amend the Settlement Agreement and Release, subject to

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the Court’s supervision and approval, under the terms and conditions set forth in the Addendum

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to Settlement Agreement and Release (“Addendum”), attached hereto as Exhibit 1; and

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WHEREAS, the Notice to Class Members of Proposed Settlement of Class Action and the

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Notice to Overlapping Class Members of Proposed Settlement of Class Action, previously

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approved by the Court, have been revised in accordance with the Addendum, copies of which are

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Exhibits A and B to the Addendum.
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 Court approves the terms and conditions of the Addendum to the Settlement

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Agreement and Release (Exhibit 1), including the revised Notice to Class

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Members of Proposed Settlement of Class Action and Notice to Overlapping Class

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Members of Proposed Settlement of Class Action, attached thereto as Exhibits A

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and B.
2.

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preliminarily approved on January 30, 2015, is hereby amended by the Addendum.

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The Settlement Agreement and Release, which the Court previously and

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-1STIPULATION RE: ADDENDUM TO SETTLEMENT AGREEMENT AND RELEASE

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3.

Except as modified by the Addendum, the terms and conditions of the Settlement
Agreement and Release are not changed.

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Dated: February 5, 2015

KERSHAW, CUTTER, & RATINOFF, LLP

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By:
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Dated: February 5, 2015

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

DANIEL J. THOMASCH
LAUREN J. ELLIOT
MICHELE MARYOTT
JULIAN POON
Gibson, Dunn & Crutcher LLP
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: February 9, 2015

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Troy L. Nunley
United States District Judge

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STIPULATION RE: ADDENDUM TO SETTLEMENT AGREEMENT AND RELEASE