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)

1
2
3
4
5
6
7
8
9

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

10
11

UNITED STATES DISTRICT COURT

12

NORTHERN DISTRICT OF CALIFORNIA

13

SAN FRANCISCO DIVISION

14
15

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

16
Plaintiff,
17

Case No.

CV 11-0043-RS

STIPULATION AND
[PROPOSED] ORDER FOR
FINAL STAY OF DEADLINES

v.
Judge:

18
19
20
21

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

Hon. Richard Seeborg

Action Filed:

Defendants.

22
23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY DEADLINES
CV 11-0043-RS
sf-3380165

Jan. 4, 2011

1

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

2

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

3

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

4
5
6

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

7

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

8

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

9

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

10

WHEREAS, on February 4, 2014, the Parties subsequently sought a further brief 9-day

11

extension, through February 13, to finalize the agreement, which was granted by the Court

12

(Docket Nos. 154 & 155);

13

WHEREAS, the Parties have finalized their Settlement Agreement and Exhibits.

14

However, while some signatures have been received, due to severe weather on the East Coast

15

preventing necessary signatories from traveling to work, there has been a delay in obtaining all

16

required signatures;

17

WHEREAS, the Parties request one final stay of seven (7) days, until February 20, 2014.

18

The Parties believe a further stay of all case deadlines is warranted to avoid unnecessary litigation

19

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

20

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

21

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

22

through February 20, 2014, by which time Plaintiff shall move for preliminary approval of the

23

class action settlement agreement.

24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY DEADLINES
CV 11-0043-RS
sf-3380165

1

1

IT IS SO STIPULATED.

2
3

Dated: February 13, 2014

MORRISON & FOERSTER LLP

4
5

By:

6

Attorneys for Defendant
STONEBRIDGE LIFE INSURANCE
COMPANY

7
8

/s/ Tiffany Cheung
TIFFANY CHEUNG

Dated: February 13, 2014

EDELSON LLC

9
10

By:

11
12

/s/ Ryan D. Andrews
RYAN D. ANDREWS
Attorneys for Plaintiff
JESSICA LEE and the class

13
14
15

Dated: February 13, 2014

LAW OFFFICES OF ALEXANDER
SKLAVOS

16
17

By:

18

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

19
20
21

PURSUANT TO STIPULATION, IT IS SO ORDERED
22
23
24
25

Dated: February 14, 2014
Hon. Richard Seeborg
United States District Judge

26
27
28
STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY DEADLINES
CV 11-0043-RS
sf-3380165

2