Lounibos v. Keypoint Government Solutions Inc

Filing 32

STIPULATION AND ORDER re 31 CONTINUING DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT filed by Donald Lounibos Case Management Statement due by 3/21/2013. Case Management Conference set for 3/28/2013 01:30 PM in Courtroom 5, 17th Floor, San Francisco. Motion Hearing set for 3/28/2013 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Hon. Edward M. Chen.. Signed by Judge Edward M. Chen on 1/24/13. (bpf, COURT STAFF) (Filed on 1/24/2013)

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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)
STIPULATION AND [PROPOSED] ORDER
CONTINUING DEADLINE FOR
FILING MOTION FOR PRELIMINARY
APPROVAL OF CLASS ACTION
SETTLEMENT

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

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STIPULATION AND [PROPOSED] CONTINUING 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 engaged in 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 time the

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Parties were not able to settle the case but agreed to continue settlement discussions. Thereafter, the

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Parties continued settlement discussions through Judge Garcia and on November 14, 2012, the Parties

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reached a settlement in principle based on the terms discussed at the mediation and based on further

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discussions and proposals made by the Parties and by Judge Garcia and have resolved this matter on a

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class-wide basis;

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WHEREAS, on January 7, 2013, the Parties filed a Joint Stipulation and Proposed Order

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Continuing Deadline for Filing Motion For Preliminary Approval of Class Action Settlement. This

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Stipulation and Proposed Ordered was entered by the Court on January 9, 2013. In particular, the

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Court’s Order reset the Case Management Conference and the hearing on the Motion for Preliminary

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Approval for February 28, 2013, and set Plaintiff’s deadline to file its Motion for Preliminary Approval

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for on or before January 24, 2013;

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WHEREAS, the Parties have been working on the terms of the settlement agreement, notice and

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claim forms but have not finalized all of these documents. As such, the parties require additional time to

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finalize the terms of the settlement agreement, as well as to finalize the claim and notice forms and to

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file the Motion for Preliminary Approval of Class Action Settlement.

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STIPULATION AND [PROPOSED] CONTINUING 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 deadline for Plaintiff to file the Motion for Preliminary Approval shall be continued from

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January 24, 2013, to February 21, 2013. The Case Management Conference and the hearing on the

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Motion for Preliminary Approval shall be continued from February 28, 2013, to March 28, 2013, or as

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soon thereafter as is convenient for the Court.

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IT IS SO STIPULATED.
DATED: January 18, 2013

NORTH BAY LAW GROUP

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

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DATED: January 18, 2013

LITTLER MENDELSON

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

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[PROPOSED] ORDER

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IS HEREBY ORDERED that:
Plaintiff’s deadline to file the Motion for Preliminary Approval shall be continued from January
24, 2013 to February 21, 2013.
The Case Management Conference and the hearing on the Motion for Preliminary Approval shall
be continued from February 28, 2013, to March 28, 2013 at 1:30 p.m. in Courtroom 5.

__________________________________
Honorable Edward M. Chen
ERED
UnitedIStates District Court Judge
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UNIT
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DATED: January __, 2013

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. Chen

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The parties having so stipulated, and GOOD CAUSE APPEARING THEREFORE, IT

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STIPULATION AND [PROPOSED] CONTINUING DEADLINErFOR FILING MOTION FOR
dwa d M
Judge E
PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

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