Lee v. Stonebridge Life Insurance Company
Filing
157
STIPULATION AND ORDER FOR FINAL STAY OF DEADLINES. Signed by Judge Richard Seeborg on 2/14/14. (cl, COURT STAFF) (Filed on 2/14/2014)
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DAN MARMALEFSKY (CA SBN 95477)
dmarmalefsky@mofo.com
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, California 90017-3543
Telephone: 213.892.5200
Facsimile: 213.892.5454
TIFFANY CHEUNG (CA SBN 211497)
TCheung@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: 415.268.7000
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 FOR
FINAL STAY OF 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, on February 4, 2014, the Parties subsequently sought a further brief 9-day
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extension, through February 13, to finalize the agreement, which was granted by the Court
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(Docket Nos. 154 & 155);
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WHEREAS, the Parties have finalized their Settlement Agreement and Exhibits.
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However, while some signatures have been received, due to severe weather on the East Coast
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preventing necessary signatories from traveling to work, there has been a delay in obtaining all
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required signatures;
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WHEREAS, the Parties request one final stay of seven (7) days, until February 20, 2014.
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The Parties believe a further stay of all case deadlines is warranted to avoid unnecessary litigation
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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 20, 2014, by which time Plaintiff shall move for preliminary approval of the
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class action settlement agreement.
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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 13, 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 13, 2014
EDELSON LLC
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By:
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/s/ Ryan D. Andrews
RYAN D. ANDREWS
Attorneys for Plaintiff
JESSICA LEE and the class
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Dated: February 13, 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: February 14, 2014
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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