Ragano-v-Michaels Stores, Inc.

Filing 50

ORDER granting 49 STIPULATION WITH PROPOSED ORDER TO CONTINUE PRELIMINARY APPROVAL HEARING filed by Anita C. Ragano, Teri McDonald. ORDER Setting Hearing on Preliminary Approval. Motion Hearing reset for 10/26/2012 10:00 AM in Courtroom 6, 17th Floor, San Francisco before Hon. Charles R. Breyer.. Signed by Judge Charles R. Breyer on 9/28/2012. (beS, COURT STAFF) (Filed on 10/1/2012)

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Scott Edward Cole, Esq. (S.B. # 160744)
Hannah R. Salassi, Esq. (S.B. # 230117)
SCOTT COLE & ASSOCIATES, APC
1970 Broadway, Ninth Floor
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Web: www.scalaw.com
Attorneys for Representative Plaintiff
and the Plaintiff Class

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ATTORNEY’S AT LAW
THE WACHOVIA TOWER
1970 BROADWAY, NINTH FLOOR
OAKLAND, CA 94612
TEL: [phone]

SCOTT COLE & ASSOCIATES, APC

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AKIN GUMP STRAUSS HAUER & FELD LLP
GREGORY W. KNOPP (SBN 237615)
GARY M. MCLAUGHLIN (SBN 217832)
[e-mail]
[e-mail]
2029 Century Park East, Suite 2400
Los Angeles, California 90067-3012
Telephone: [phone]
Facsimile:
310-229-1001
Attorneys for Defendant
Michaels Stores, Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

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ANITA C. RAGANO, TERI
MCDONALD, individually, and on
behalf of all others similarly situated,
Plaintiffs,

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vs.

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MICHAELS STORES, INC.,
and DOES 1 through 100, inclusive,

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Defendants.

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Case No. CV 11-3908 CRB
CLASS ACTION
JOINT STIPULATION TO CONTINUE
PRELIMINARY APPROVAL HEARING

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-1JOINT STIPULATION AND [PROPOSED ORDER] TO CONTINUE PRELIMINARY APPROVAL HEARING

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Representative Plaintiffs Anita Ragano and Teri McDonald (“Plaintiffs”),

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individually, and on behalf of all others similarly situated, and defendant Michaels Stores, Inc.

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(“Defendant”), by and through their respective counsel of record, hereby stipulate and request that

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the Court continue the preliminary approval hearing scheduled for October 12, 2012 to October 26,

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2012.

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The parties’ Request is made on the following grounds:

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1.

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ATTORNEY’S AT LAW
THE WACHOVIA TOWER
1970 BROADWAY, NINTH FLOOR
OAKLAND, CA 94612
TEL: [phone]

SCOTT COLE & ASSOCIATES, APC

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On August 7, 2012, the parties conducted a mediation and have entered into

settlement negotiations.
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The parties are currently resolving final details of the settlement agreement, and need

additional time to do so prior to filing a motion for preliminary approval.
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Accordingly, the parties respectfully request that the Court enter the Order jointly

proposed by the parties.

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IT IS SO STIPULATED.

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Dated: September 27, 2012

SCOTT COLE & ASSOCIATES, APC

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By:

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/s/ Hannah R. Salassi
Hannah R. Salassi, Esq.
Attorneys for the Representative Plaintiffs
and the Plaintiff Class

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Dated: September 27, 2012
AKIN GUMP STRAUSS HAUER & FELD LLP

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By:

/s/ Gary McLaughlin
Gary McLaughlin, Esq.
Attorneys for Defendant Michaels Stores, Inc.

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-2JOINT STIPULATION AND [PROPOSED ORDER] TO CONTINUE PRELIMINARY APPROVAL HEARING

[PROPOSED] ORDER

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UPON GOOD CAUSE APPEARING, AND PURSUANT TO STIPULATION

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BETWEEN THE PARTIES, THE COURT HEREBY ORDERS AS FOLLOWS: The October

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12, 2012 Preliminary Approval Hearing is hereby continued to October 26, 2012 at 10:00 a.m.

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IT IS SO ORDERED.

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IT IS S

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Judge C

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ATTORNEY’S AT LAW
THE WACHOVIA TOWER
1970 BROADWAY, NINTH FLOOR
OAKLAND, CA 94612
TEL: [phone]

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SCOTT COLE & ASSOCIATES, APC

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Honorable Charles Breyer
United States District Judge RED
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Dated: ______________________
September 28, 2012

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-3JOINT STIPULATION AND [PROPOSED ORDER] TO CONTINUE PRELIMINARY APPROVAL HEARING