Lee v. Stonebridge Life Insurance Company

Filing 155

STIPULATION AND ORDER TO FURTHER STAY DEADLINES. Signed by Judge Richard Seeborg on 2/5/14. (cl, COURT STAFF) (Filed on 2/5/2014)

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DAN MARMALEFSKY (CA SBN 95477)
[e-mail]
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, California 90017-3543
Telephone: [phone]
Facsimile: 213.892.5454
TIFFANY CHEUNG (CA SBN 211497)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Defendant
STONEBRIDGE LIFE INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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JESSICA LEE, individually and on behalf of a
class of similarly situated individuals,

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Plaintiff,
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Case No.

CV 11-0043-RS

STIPULATION AND
[PROPOSED] ORDER TO
FURTHER STAY DEADLINES

v.
Judge:

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STONEBRIDGE LIFE INSURANCE
COMPANY, a Vermont corporation, and
TRIFECTA MARKETING GROUP LLC, a
Florida limited liability company,

Hon. Richard Seeborg

Action Filed:

Defendants.

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STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY DEADLINES
CV 11-0043-RS
sf-3380165

Jan. 4, 2011

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Plaintiff Jessica Lee, Defendant Stonebridge Life Insurance Company (“Stonebridge”),

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and Defendant Trifecta Marketing Group, LLC (“Trifecta”) (collectively the “Parties”), by and

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through their respective counsel of record, hereby enter into the following stipulation:

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WHEREAS, the Parties have reached a class action settlement in principle that would
resolve all of the claims of Plaintiff and the Class against both Stonebridge and Trifecta;
WHEREAS, the Court has approved stipulations between the Parties that stayed all

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activity in this Action, including all hearings and discovery and motion deadlines, for a total

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period of approximately 11 weeks to allow the Parties to work on a class action settlement

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agreement and submit it to the Court for preliminary approval (Docket No. 149);

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WHEREAS, the Parties agreed to submit a joint status report to the Court upon the
expiration of current stay to inform the Court of the status of the settlement;
WHEREAS, the Parties have been diligently preparing and exchanging drafts of the class

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action settlement agreement and related documents, but seek a brief 9-day extension of the

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current stay, through February 13, 2014, to work on finalizing the agreement;

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WHEREAS, the Parties believe a further stay of all case deadlines is warranted to avoid

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unnecessary litigation expenses and to conserve the resources of both the Parties and the Court;

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THEREFORE, subject to the approval of the Court, the Parties agree and stipulate that

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this Action, including all hearings and discovery and motion deadlines, shall remain stayed

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through February 13, 2014. The Parties agree to submit a joint status report on the day that this

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stay is scheduled to expire to inform the Court of the status of the settlement, unless Plaintiff has

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moved for preliminary approval of the class action settlement agreement on or before such time.

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STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY DEADLINES
CV 11-0043-RS
sf-3380165

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IT IS SO STIPULATED.

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Dated: February 4, 2014

MORRISON & FOERSTER LLP

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By:

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Attorneys for Defendant
STONEBRIDGE LIFE INSURANCE
COMPANY

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/s/ Tiffany Cheung
TIFFANY CHEUNG

Dated: February 4, 2014

EDELSON P.C.

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By:

/s/ Ryan D. Andrews
RYAN D. ANDREWS

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Attorneys for Plaintiff
JESSICA LEE and the class

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Dated: February 4, 2014

LAW OFFFICES OF ALEXANDER
SKLAVOS

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By:

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/s/ Alexander E. Sklavos
ALEXANDER E. SKLAVOS
Attorney for Defendant
TRIFECTA MARKETING GROUP,
LLC

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PURSUANT TO STIPULATION, IT IS SO ORDERED
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Dated: 2/5/14
Hon. Richard Seeborg
United States District Judge

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STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY DEADLINES
CV 11-0043-RS
sf-3380165

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