Khalilpour v. Cellco Partnership

Filing 48

STIPULATION AND ORDER. Signed by Judge Richard Seeborg on 3/22/11. (cl, COURT STAFF) (Filed on 3/22/2011)

*E-Filed 3/22/11* JEFFREY D. MEYER MOULTON & MEYER, LLP 800 Taft Houston, Texas 77019 [phone] Telephone [phone] Telecopier Pro hac vice application to be filed GEORGE L. HAMPTON IV, State Bar No. 144433 HAMPTONHOLLEY LLP 2101 East Coast Highway, Suite 260 Corona del Mar, CA 92625 Telephone: [phone] Facsimile: [phone] CHRISTOPHER A. BANDAS BANDAS LAW FIRM, P.C. 500 North Shoreline, Suite 1020 Corpus Christi, Texas 78471 Telephone: [phone] Facsimile: [phone] Pro hac vice application to be filed *Additional Counsel on last page 13 14 15 16 17 18 19 20 21 22 23 24 25 Defendants. 26 27 28 -1STIPULATION AND [PROPOSED] ORDER Case No. C 09-02712 RS

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Attorneys for Plaintiff MAHBOD KHALILPOUR and Plaintiff Class UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

MAHBOD KHALILPOUR, on behalf of himself and all others similarly situated, Plaintiffs, v. CELLCO PARTNERSHIP d/b/a VERIZON WIRELESS; and DOES 1 through 10, inclusive,

Case No. C 09-02712 RS STIPULATION AND [PROPOSED] ORDER

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WHEREAS, on August 25, 2010, the parties informed the Court that they had reached a settlement on a class-wide basis in the above-entitled matter; WHEREAS, the parties previously agreed that the deadline for Plaintiff to file a motion for preliminary approval of the class action settlement would be extended from January 13, 2011 to March 21, 2011 to allow for the completion of confirmatory discovery and the documentation required for a class action settlement; WHEREAS, the parties are in the process of completing the documentation required for a class action settlement; WHEREAS, certain issues related to confirmatory discovery have arisen; WHEREAS, the parties require additional time to determine if they can resolve the discovery issues and complete the documentation required for a class action settlement; WHEREAS, if the parties cannot reach an agreement on the discovery issues, they may seek assistance from the Court; THEREFORE, it is hereby stipulated and agreed to by and between the parties, through their counsel of record, that the deadline for Plaintiff to file a motion for preliminary approval of the class action settlement be extended from March 21, 2011 to April 11, 2011.

DATED: March 18, 2011 20 21 22 23 24 25 26 27 28
STIPULATION AND [PROPOSED] ORDER Case No. C 09-02712 RS

ONGARO BURTT & LOUDERBACK LLP By: /s/ David. R. Ongaro David R. Ongaro

Attorneys for Plaintiff MAHBOD KHALILPOUR

DATED: March 18, 2011

MORRISON & FOERSTER LLP By: /s/ Penelope Preovolos Penelope Preovolos

Attorneys for Defendant CELLCO PARTNERSHIP d/b/a Verizon Wireless -2-

1 2 3 4 DATED: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3STIPULATION AND [PROPOSED] ORDER Case No. C 09-02712 RS

PURSUANT TO STIPULATION, IT IS SO ORDERED.

3/22/11

By: United States District Judge