Morales et al v. Leggett & Platt Incorporated et al

Filing 58

STIPULATION and ORDER signed by District Judge John A. Mendez on 5/21/2019 ORDERING the time for Plaintiffs to file their motion for preliminary approval is EXTENDED to 5/24/2019. The hearing date and time shall remain 6/18/2019 at 1:30 p.m. (Washington, S)

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MALLISON & MARTINEZ
Stan S. Mallison (SBN 184191)
Hector R. Martinez (SBN 206336)
Liliana Garcia (SBN 311396)
1939 Harrison Street, Suite 730
Oakland, California 94612
Telephone: [phone]
Facsimile: 510-832-1101

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Attorneys for Plaintiffs
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SHOOK, HARDY & BACON L.L.P.
Tammy B. Webb (SBN 227593)
[e-mail]
One Montgomery, Suite 2700
San Francisco, California 94104-2828
Telephone: [phone]
Facsimile: 415-391-0281

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Carrie A. McAtee*
[e-mail]
2555 Grand Blvd.
Kansas City, Missouri 64108
Telephone: [phone]
Facsimile: 816-421-5547

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*admitted pro hac vice

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Attorneys for Defendants
Leggett & Platt, Incorporated
and L&P Financial Services Co.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION

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EDGAR MORALES, SALVADOR MAGAÑA, )
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and MATTHEW BAGU,
on behalf of themselves, the State of California, )
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and all other similarly situated individuals,
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Plaintiffs,
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vs.
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LEGGETT & PLATT, INCORPORATED, a )
Missouri Corporation, L&P FINANCIAL
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SERVICES CO., a Delaware Corporation, and )
DOES 1 through 20, inclusive,
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Defendants.
)
)

Case No. 2:15-cv-01911-JAM-EFB
STIPULATION AND JOINT
APPLICATION FOR EXTENSION OF
TIME TO FILE MOTION FOR
PRELIMINARY APPROVAL OF CLASS
SETTLEMENT AND ORDER

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STIPULATION AND PROPOSED ORDER

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Plaintiffs EDGAR MORALES, SALVADOR MAGAÑA, and MATTHEW BAGU and

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Defendants LEGGETT & PLATT, INCORPORATED and L&P FINANCIAL SERVICES CO., by

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and through their respective counsel, submit the following stipulation.

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The parties respectfully submit this stipulation to extend the time within which Plaintiffs
must file their motion for preliminary approval of the class settlement.

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STIPULATION

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The parties, through their respective counsel hereby stipulate as follows:

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1.

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The parties have finalized the Settlement Agreement and Release (“Agreement”) and

obtained all signatures necessary to its execution.
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Counsel for Plaintiffs, Liliana Garcia, reserved a hearing date of June 18, 2019 at 1:30

p.m. for the court to hear Plaintiffs’ motion for preliminary approval.
3.

Pursuant to the terms of the Agreement, Counsel for Plaintiffs, Liliana Garcia, emailed

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Counsel for Defendants, Carrie McAtee, drafts of the Class Notice Packet for her review on May

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16, 2019.

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4.

Due to scheduling conflicts, Counsel for Defendants is not in a position to review the

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documents and consult with her clients prior to Plaintiffs’ deadline to file their motion for

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preliminary approval.

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5.

The courtroom deputy to Judge John A. Mendez informed Plaintiffs’ Counsel that the

next available hearing date is July 16, 2019 at 1:30 p.m.
6.

Counsel for Plaintiffs agree that the motion will be ready for filing no later than

Friday, May 24, 2019.

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Therefore, the parties hereby stipulate that the date for filing the motion for preliminary

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approval should be extended to no later than May 24, 2019 and respectfully apply to this court for

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an order doing so based on good cause shown.

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IT IS SO STIPULATED:

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Dated: May 21, 2019

MALLISON & MARTINEZ

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By: /s/ Liliana Garcia
Liliana Garcia
STIPULATION AND ORDER

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Attorneys for Plaintiffs

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SHOOK, HARDY & BACON L.L.P.

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By: /s/ Carrie A. McAtee

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Carrie A. McAtee

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Attorneys for Defendants
Leggett & Platt, Incorporated
and L&P Financial Services Co.

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STIPULATION AND ORDER

ORDER

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Upon a showing of good cause, IT IS HEREBY ORDERED THAT the time for Plaintiffs to

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file their motion for preliminary approval is hereby extended to May 24, 2019. The hearing date

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and time shall remain June 18, 2019 at 1:30 p.m.

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Dated: 5/21/2019

/s/ John A. Mendez____________
United States District Court Judge

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STIPULATION AND ORDER