Lounibos v. Keypoint Government Solutions Inc

Filing 27

STIPULATION AND ORDER RESETTING CMC to 2/14/13 at 1:30 p.m. AND SETTING HEARING ON MOTION FOR PRELIMINARY APPROVAL OF ASETTLEMENT re 26 Notice (Other), filed by Donald Lounibos Case Management Statement due by 2/7/2013. Further Case Manageme nt Conference set for 2/14/2013 01:30 PM in Courtroom 5, 17th Floor, San Francisco. Motion Hearing set for 2/14/2013 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Hon. Edward M. Chen. Motion due by 1/10/2013.. Signed by Judge Edward M. Chen on 11/20/12. (bpf, COURT STAFF) (Filed on 11/20/2012)

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STEVEN L. HAMMOND (SBN 220521)
Hammond Law Group, P.C.
One Embarcadero Center, Suite 2360
San Francisco, California 94111
Telephone: [phone]
DAVID HARRIS (SBN 215224)
North Bay Law Group
116 E Blithedale Avenue, Suite 2
Mill Valley, CA 94941
Telephone: [phone]
FRANCIS SHEHADEH (SBN 251130)
Law Office of Francis J. Shehadeh
819 Eddy Street
San Francisco, CA 94109
Telephone: [phone]
Attorneys for Plaintiff
DONALD LOUNIBOS
MICHELLE B. HEVERLY (SBN 178660)
KARIN M. COGBILL (SBN 244606)
LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
Telephone: [phone]
Attorneys for Defendant
KEYPOINT GOVERNMENT SOLUTIONS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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DONALD LOUNIBOS, individually and
on behalf of all others similarly situated,

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Case No. 12-CV-0636 (EMC)
NOTICE OF SETTLEMENT; JOINT
STIPULATION AND [PROPOSED] ORDER
TO VACATE CASE MANAGEMENT
CONFERENCE AND SET DEADLINE FOR
FILING MOTION FOR PRELIMINARY
APPROVAL OF CLASS ACTION
SETTLEMENT
(CMC reset for 2/14/13 at 1:30 p.m.)

Plaintiff,
v.
KEYPOINT GOVERNMENT
SOLUTIONS, INC., a Delaware
Corporation, and Does 1-10, inclusive,
Defendants.

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NOTICE OF SETTLEMENT; JOINT STIPULATION AND [PROPOSED] ORDER TO VACATE CASE MANAGEMENT CONFERENCE AND
SET DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

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STIPULATION

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Plaintiff Donald Lounibos (“Plaintiff”) and Defendant Keypoint Government Solutions, Inc.
(“Defendant”) (collectively “the Parties”), stipulate and agree as follows:

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WHEREAS, on November 2, 2012, the Parties had a full day mediation session with the

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Hon. David Garcia (Ret.) (“Judge Garcia”) at JAMS in San Francisco, California, at which the Parties

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were not able to settle the case but agreed to continue settlement discussions;

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WHEREAS, the Parties since the last mediation session continued settlement discussions

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through Judge Garcia and on November 14, 2012, the Parties reached a settlement in principle based on

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the terms discussed at the mediation and based on further discussions and proposals made by the Parties

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and by Judge Garcia and have resolved this matter on a class-wide basis;

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WHEREAS, this case currently is scheduled for a Case Management Conference on November
30, 2012 at 10:30 A.M. (“the Case Management Conference”);

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WHEREAS, the Parties believe it would conserve judicial resources and promote efficiency to
vacate the Case Management Conference in light of the resolution of this case;

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WHEREAS, the Parties have agreed that Plaintiff’s Motion for Preliminary Approval of

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Class Action Settlement (“Motion For Preliminary Approval”) shall be filed on or before January 10,

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2013, and shall be set for hearing on February 14, 2013, or as soon thereafter as is convenient for the

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Court;

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WHEREAS, there is no trial date set for this case;

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NOTICE OF SETTLEMENT; JOINT STIPULATION AND [PROPOSED] ORDER TO VACATE CASE MANAGEMENT CONFERENCE AND
SET DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

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IT IS HEREBY STIPULATED by the Parties herein, through their counsel of record, as
follows:
The Case Management Conference shall be vacated and the Motion for Preliminary Approval

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shall be filed on or before January 10, 2013, and shall be set for hearing on February 14, 2013, or as soon

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thereafter as is convenient for the Court.

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IT IS SO STIPULATED.
DATED: November 19, 2012

NORTH BAY LAW GROUP

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___________/s/___________________
David S. Harris
Attorney For Plaintiff
DONALD LOUNIBOS

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DATED: November 19, 2012

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LITTLER MENDELSON
____________/s/__________________
Karin Cogbill
Attorneys for Defendant
KEYPOINT GOVERNMENT SOLUTIONS

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[PROPOSED] ORDER

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The parties having so stipulated, and GOOD CAUSE APPEARING THEREFORE, IT
IS HEREBY ORDERED that:

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reset for 2/14/13 at 1:30
pm.
The Case Management Conference set for November 30, 2012, at 10:30 a.m. is VACATED.

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Plaintiff shall file the Motion for Preliminary Approval on or before January 10, 2013.

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The hearing on the Motion for Preliminary Approval shall take place on February 14, 2013, at
1:30 p.m. in Courtroom 5.

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Judge E

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__________________________________
ERED
HonorableSEdwardD Chen
O OR M. D
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I States DistrictFIE Judge
UnitedT
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DATED: November __, 2012

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NOTICE OF SETTLEMENT; JOINT STIPULATION AND [PROPOSED]E
ORDER TO VACATE CASE MANAGEMENT CONFERENCE AND
C
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SET DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
F

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UNIT
ED

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