Khanna v. Inter-Con Security Systems, Inc. et al

Filing 66

STIPULATION and ORDER signed by Judge Kimberly J. Mueller on 4/3/2013 ORDERING the schedule of relevant dates and deadlines is APPROVED. (Zignago, K.)

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DAVID P. MASTAGNI, ESQ. (SBN 57721)
DAVID E. MASTAGNI, ESQ. (SBN 204244)
JAMES B. CARR, ESQ. (SBN 53274)
ISAAC S. STEVENS, ESQ. (SBN 251245)
JEFFREY R. A. EDWARDS, ESQ. (SBN 265597)
MASTAGNI, HOLSTEDT, AMICK,
MILLER & JOHNSEN
A Professional Corporation
1912 “I” Street
Sacramento, California 95811-3151
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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PRIYANKA KHANNA et al.,
Plaintiffs,

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INTER-CON SECURITY SYSTEMS, INC., a
California Corporation D/B/A/
HEALTHCARE SECURITY SERVICES
GROUP, a putative independent entity, et al.,

[FLSA COLLECTIVE ACTION/CLASS
ACTION]

v.

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CASE NO. 2:09-cv-02214-KJM-GGH

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NEW SCHEDULE; ORDER

Defendants.

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On March 21, 2013, the Court directed the parties to submit a new proposed schedule setting the

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same day for objections to settlement and fees, after the completed fee motion has been filed. ECF 63-

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11. The Parties propose the following settlement notice and approval schedule, which is incorporated

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into the accompanying Proposed Order.

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///
NEW SCHEDULE

KHANNA, et al. v. INTER-CON, et al.
Case No. 2:09-cv-02214-KJM-GGH

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NEW PROPOSED SCHEDULE

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April 20, 2013
(30 days after preliminary approval)

Deadline for Inter-Con to provide Claims
Administrator with class data

May 20, 2013
(30 days after submission of class data
to Claims Administrator)

Deadline for Claims Administrator to mail the Class
Notice and Claim Forms to all class members

June 19, 2013
(30 days after mailing of Class Notice)

Last day for eligible class members to submit election
not to participate in the Settlement

June 24, 2013
(No less than 10 days before close of
time for class members to submit
claims)

Last day for Settlement Administrator to mail a
reminder postcard to class members who have not yet
submitted claims

July 4, 2013
(45 days after mailing of Class Notice)

Last day for class members to submit claims

July 3, 2013
(14 days after deadline for submission
of the elections to not participate)

Last day for Claims Administrator to the notify the
parties of the valid elections not to participate
received

July 17, 2013
(14 days after the Claims
Administrator notifies the parties of the
valid elections not to participate
received after deadline for submission
of the elections to not participate)

Last day for Inter-Con to rescind the Settlement, thus
making the Settlement and all actions taken in its
furtherance null and void

October 2, 2013
(No less than 30 days before the final
approval hearing)

Last day for parties to file and serve joint motion for
final approval of Settlement, and for Plaintiffs to file
request for attorneys’ fees, costs, and Class
Representative payment

October 18, 2013
(No less than 14 days before the final
approval hearing)

Last day for class members to submit written
objections to the Class Counsel’s request for fees and
any notices of intent to appear at the final approval
hearing and objections to the Settlement and notices
of intent to appear at the final approval hearing

October 25, 2013
(No less than 5 court days prior to the
final approval hearing)

Last day for Class Counsel to file with the Court, a
declaration by the Claims Administrator that
evidences the Claims Administrator’s due diligence
in the claims administration process and the responses
from the class

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NEW SCHEDULE

KHANNA, et al. v. INTER-CON, et al.
Case No. 2:09-cv-02214-KJM-GGH

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November 1, 2013
No later than 30 days after the
Settlement Effective Date

Final approval hearing
Last day for Inter-Con to transfer the settlement
funds, including any attorneys’ fess and costs and
service payment the court may award to the Claims
Administrator

No later than 60 days after the
Settlement Effective Date

Last day for the Claims Administrator to disburse
settlement amount due to each class member, and
any class representative service payment and/or
attorneys’ fees the Court may award.

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Dated: March 29, 2013

MASTAGNI, HOLSTEDT, AMICK,
MILLER & JOHNSEN

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/s/ Jeffrey R.A. Edwards
JEFFREY R. A. EDWARDS
Attorneys for Plaintiffs

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Dated: March 29, 2013

PAUL HASTINGS

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/s/ Jeffrey Grube
JEFFREY GRUBE
Attorney for Defendants

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NEW SCHEDULE

KHANNA, et al. v. INTER-CON, et al.
Case No. 2:09-cv-02214-KJM-GGH

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ORDER

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The Court has carefully reviewed the Settlement Agreement, the Stipulation for Approval of

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Settlement and the Proposed Order, together with relevant Exhibits. Based upon a review of the record,

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the representations of the parties, and good cause appearing.

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IT IS ORDERED that:

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Based on the papers submitted by the parties in support of this motion, the Court adopts the following

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schedule of relevant dates and deadlines:

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April 20, 2013
(30 days after preliminary approval)

Deadline for Inter-Con to provide Claims
Administrator with class data

May 20, 2013
(30 days after submission of class data
to Claims Administrator)

Deadline for Claims Administrator to mail the Class
Notice and Claim Forms to all class members

June 19, 2013
(30 days after mailing of Class Notice)

Last day for eligible class members to submit election
not to participate in the Settlement

June 24, 2013
(No less than 10 days before close of
time for class members to submit
claims)

Last day for Settlement Administrator to mail a
reminder postcard to class members who have not yet
submitted claims

July 4, 2013
(45 days after mailing of Class Notice)

Last day for class members to submit claims

July 3, 2013
(14 days after deadline for submission
of the elections to not participate)

Last day for Claims Administrator to the notify the
parties of the valid elections not to participate
received

July 17, 2013
(14 days after the Claims
Administrator notifies the parties of the
valid elections not to participate
received after deadline for submission
of the elections to not participate)

Last day for Inter-Con to rescind the Settlement, thus
making the Settlement and all actions taken in its
furtherance null and void

October 2, 2013
(No less than 30 days before the final
approval hearing)

Last day for parties to file and serve joint motion for
final approval of Settlement, and for Plaintiffs to file
request for attorneys’ fees, costs, and Class
Representative payment

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NEW SCHEDULE

KHANNA, et al. v. INTER-CON, et al.
Case No. 2:09-cv-02214-KJM-GGH

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October 18, 2013
(No less than 14 days before the final
approval hearing)

Last day for class members to submit written
objections to the Class Counsel’s request for fees and
any notices of intent to appear at the final approval
hearing and objections to the Settlement and notices
of intent to appear at the final approval hearing

October 25, 2013
(No less than 5 court days prior to the
final approval hearing)

Last day for Class Counsel to file with the Court, a
declaration by the Claims Administrator that
evidences the Claims Administrator’s due diligence in
the claims administration process and the responses
from the class

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November 1, 2013

Final approval hearing

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No later than 30 days after the
Settlement Effective Date

Last day for Inter-Con to transfer the settlement
funds, including any attorneys’ fess and costs and
service payment the court may award to the Claims
Administrator

No later than 60 days after the
Settlement Effective Date

Last day for the Claims Administrator to disburse
settlement amount due to each class member, and
any class representative service payment and/or
attorneys’ fees the Court may award

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DATED: April 3, 2013.

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UNITED STATES DISTRICT JUDGE

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NEW SCHEDULE

KHANNA, et al. v. INTER-CON, et al.
Case No. 2:09-cv-02214-KJM-GGH

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