Story v. Mammoth Mountain Ski Area, LLC

Filing 79

STIPULATION and ORDER signed by District Judge John A. Mendez on 1/16/18: Plaintiff shall have a four day extension of time to and including January 26, 2018 to file and serve Plaintiff's Motion for Final Approval and Motion for Attorneys' Fees. (Kaminski, H)

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GLANCY PRONGAY & MURRAY LLP
Lionel Z. Glancy (SBN 134180)
Mark S. Greenstone (SBN 199606)
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
[Additional Counsel for Plaintiff on Signature Page]

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KIRKLAND & ELLIS LLP
Jeffrey L. Willian, P.C. (pro hac vice)
[e-mail]
Jordan M. Heinz (pro hac vice)
[e-mail]
300 North LaSalle Street
Chicago, IL 60654
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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PAUL STORY, individually and on behalf of all
others similarly situated,

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JOINT STIPULATION AND ORDER RE
EXTENSION OF TIME FOR PLAINTIFF TO
FILE MOTION FOR FINAL APPROVAL
AND MOTION FOR ATTORNEYS’ FEES

Plaintiff,

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v.
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Case No. 2:14-cv-02422-JAM-DB

MAMMOTH MOUNTAIN SKI AREA, LLC, a
Delaware limited-liability company,

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Defendant.

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361835.1 MAMMOTHMOUNTAIN

JT STIP & [PROPOSED] ORDER RE EXTENSION OF TIME FOR PLTF TO FILE FINAL APPROVAL & FEE MTNS

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Plaintiff Paul Story and Defendant Mammoth Mountain Ski Area, LLC hereby submit the following
Joint Stipulation And [Proposed] Order Re Extension Of Time For Plaintiff To Motion For Final Approval
and Motion For Attorneys’ Fees.
WHEREAS, on November 9, 2017 this Court issued its Order Granting Preliminary Approval Of
Class-Action Settlement of the within matter (“Preliminary Approval Order”) [ECF 77];
WHEREAS, pursuant to the Preliminary Approval Order, the Settlement Administrator duly sent out
the Class Notice on December 20, 2017;
WHEREAS, pursuant to the Preliminary Approval Order, all papers in support of final approval of the
Settlement are currently due to be filed by January 22, 2018 (see ECF 77 at ¶7(d) (providing that all papers
in support of final approval of the Settlement shall be filed thirty-two (32) calendar days after the Settlement
Administrator sends the Class Notice));
WHEREAS, due to the press of business and to permit time to receive and analyze a detailed status
report from the Claims Administrator, Class Counsel desires a brief four day extension of time to file
Plaintiff’s Motion for Final Approval and Motion for Attorneys’ Fees;
WHEREAS, the brief four day extension stipulated to herein will not prejudice any Class Member
given that the deadline to file an objection to the Settlement or submit a Request for Exclusion is not until
February 20, 2018 (see id. at ¶7(c) (providing that Class Members shall have sixty (60) calendar days after
the Settlement Administrator sends the Class Notice to object or opt out of the Settlement)). Thus, even if
the brief extension requested herein is granted, Class Members will have over three weeks to review
Plaintiff’s papers before the objection/exclusion deadline;
WHEREAS, Plaintiff has made no previous request for extension relating to the matter set forth
herein;
NOW, THEREFORE, IT IS HEREBY AGREED AND STIPULATED, subject to the approval of the
Court, as follows: Plaintiff shall have a four day extension of time to and including January 26, 2018 to file
and serve Plaintiff’s Motion for Final Approval and Motion for Attorneys’ Fees.

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361835.1 MAMMOTHMOUNTAIN

JT STIP & [PROPOSED] ORDER RE EXTENSION OF TIME FOR PLTF TO FILE FINAL APPROVAL & FEE MTNS

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Dated: January 16, 2018

GLANCY PRONGAY & MURRAY LLP

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By: s/ Mark S. Greenstone
Lionel Z. Glancy (SBN 134180)
Mark S. Greenstone (SBN 199606)
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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JAURIGUE LAW GROUP
Michael J. Jaurigue (SBN 208123)
Abigail A. Zelenski (SBN 228610)
David Zelenski (SBN 231768)
114 North Brand Boulevard, Suite 200
Glendale, California 91203
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff

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Dated: January 16, 2018

KIRKLAND & ELLIS LLP

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By: s/ Jordan M. Heinz
Jeffrey L. Willian, P.C. (pro hac vice)
[e-mail]
Jordan M. Heinz (pro hac vice)
[e-mail]
KIRKLAND & ELLIS LLP
300 North LaSalle Street
Chicago, IL 60654
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant Mammoth
Mountain Ski Area, LLC

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361835.1 MAMMOTHMOUNTAIN

JT STIP & [PROPOSED] ORDER RE EXTENSION OF TIME FOR PLTF TO FILE FINAL APPROVAL & FEE MTNS
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IT IS SO ORDERED.

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Dated: 1/16/2018

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/s/ John A. Mendez______
Hon. John A. Mendez
U.S. District Court Judge

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361835.1 MAMMOTHMOUNTAIN

JT STIP & [PROPOSED] ORDER RE EXTENSION OF TIME FOR PLTF TO FILE FINAL APPROVAL & FEE MTNS
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