Gomez v. Perot Systems Corporation

Filing 53

STIPULATION AND ORDER: Plaintiff's Motion for preliminary approval of the class action settlement set to be heard on 9/17/10 is submitted on the papers with no appearance and no oral argument. The Case Management Conference set for 9/17/10 is off calendar. (tdm, COURT STAFF) (Filed on 9/2/2010)

Gomez v. Perot Systems Corporation

Doc. 53

CHAVEZ & GERTLER LLP 1 JONATHAN E. GERTLER (Bar. No. 111531) CHRISTIAN SCHREIBER (Bar No. 245597) 2 42 Miller Avenue 3 Mill Valley, CA 94941 Tel: [phone] Fax: [phone] SCHNEIDER WALLACE 5 COTTRELL BRAYTON KONECKY LLP TODD M. SCHNEIDER (Bar No. 158253) 6 JOSHUA G. KONECKY (Bar No. 182897) 7 LISA M. BOWMAN (Bar No. 253843) 180 Montgomery Street, Suite 2000 8 San Francisco, CA 94104 Tel: [phone] Fax: [phone] Attorneys for Plaintiff ANGELITA GOMEZ and the proposed class 10 11 JACKSON LEWIS LLP JOANNA L. BROOKS (Bar No. 182986) 12 ANNE V. LEINFELDER (Bar No. 230272) DOUGLAS M. BRIA (Bar No. 226966) 13 199 Fremont Street, 10th Floor San Francisco, CA 94105 14 Tel: [phone] Fax: [phone] THE MILLER LAW GROUP 16 TIMOTHY C. TRAVELSTEAD (Bar No. 215260) 111 Sutter Street 17 San Francisco, CA 94104-4547 18 Tel: [phone] Fax: [phone] Attorneys for Defendant PEROT SYSTEMS CORPORATION 20 21 22 ANGELITA GOMEZ, 23 24 25 Plaintiff, vs. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case No. CV-08-03337 SC STIPULATION TO SUBMIT MOTION FOR PRELIMINARY APPROVAL FOR RULING ON THE PAPERS WITHOUT HEARING Complaint filed: May 27, 2008 The Honorable Samuel Conti

PEROT SYSTEMS CORPORATION, a 26 Delaware Corporation; and DOES 1 to 50, 27 28 Defendants.

STIPULATION TO SUBMIT MOTION FOR PRELIMINARY APPROVAL FOR RULING ON THE PAPERS Gomez v. Perot Systems Corp., Case No. CV-08-03337 SC Dockets.Justia.com

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WHEREAS, the parties reached the core terms of a class action settlement in the above-

2 captioned case on June 19, 2010; 3 WHEREAS, the parties executed the full class action settlement agreement on August 31,

4 2010 and September 1, 2010; 5 WHEREAS, Plaintiff filed a Motion for preliminary approval of the class action settlement

6 on September 1, 2010; 7 WHEREAS, the foregoing papers include, inter alia, the fully executed class action

8 settlement agreement, the text and procedures for notice to the settlement class; and the other 9 materials required by Fed. R. Civ. P. 23; 10 WHEREAS, the foregoing materials also include a proposed order setting dates for class

11 notice, requests for exclusions by class members, objections, the motion for attorneys' fees and 12 costs pursuant to Fed. R. Civ. P. 23(h), and a final fairness hearing date to be set by the Court; 13 WHEREAS, the motion is noticed for hearing on September 17, 2010, in the event the Court

14 wishes the parties to appear; 15 WHEREAS, the Court already has scheduled a Case Management Conference to take place

16 on September 17, 2010; 17 18 WHEREAS, the motion for preliminary approval is unopposed; WHEREAS, given that the motion is unopposed, all briefing respecting the motion will be

19 submitted earlier than two weeks prior to the September 17, 2010, which would otherwise be the 20 date that all reply papers would need to be filed under the Local Civil Rules if the matter were 21 opposed; 22 WHEREAS, the parties stipulate to have the matter submitted on the papers if the Court

23 does not require a hearing, or alternatively, request the Court to consider the motion on September 24 17, 2010. 25 26 1. STIPULATION AND JOINT REQUEST In light of the foregoing, IT IS STIPULATED between the parties that the Motion

27 for Preliminary Approval of the Class Action Settlement can be submitted on the papers without a 28
STIPULATION TO SUBMIT MOTION FOR PRELIMINARY APPROVAL FOR RULING ON THE PAPERS Gomez v. Perot Systems Corp., Case No. CV-08-03337 SC

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