Lounibos v. Keypoint Government Solutions Inc

Filing 51

STIPULATION AND ORDER re 50 STIPULATION WITH PROPOSED ORDER Continuing Plaintiff's Deadline to File New Motion for Preliminary Approval of Class Action Settlement filed by Donald Lounibos. Motion due by 11/14/2013. Case Management Statement due by 1/8/2014. Further Case Management Conference set for 1/22/2014 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on October 29, 2013. (wsn, COURT STAFF) (Filed on 10/29/2013)

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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]
Attorneys for Plaintiff
DONALD LOUNIBOS

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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 (JST)
STIPULATION AND [PROPOSED] ORDER
CONTINUING PLAINTIFF’S DEADLINE
TO FILE NEW MOTION FOR
PRELIMINIARY APPROVAL OF CLASS
ACTION SETTLEMENT

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

Assigned to Honorable Jon S. Tigar
450 Golden Gate Avenue
San Francisco, CA 94102

Defendants.

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Date:

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STIPULATION

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The parties hereby stipulate as follows:

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WHEREAS, on July 12, 2013, the Court issued an Order Denying Motion for Preliminary

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Approval of Class Action Settlement (“Order”) (docket number 45). In particular, the Order, stated,

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“Lounibos’ motion for preliminary approval of the proposed settlement is denied without prejudice.

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Lounibos may file a new motion for preliminary approval of the proposed settlement that cures each of

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the deficiencies identified in this Order within sixty days of the date this order is filed. A case

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management conference will be held on October 2, 2013 at 2:00 p.m.”
WHEREAS, on October 8, 2013, the Court entered an Order continuing Plaintiff’s Deadline to

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File New Motion for Preliminary Approval of Class Action Settlement. Pursuant to the October 8, 2013,
Order, Plaintiff’s current deadline to file a new Motion is October 30, 2013.
WHEREAS, the parties have come to agreement on all material terms to a modified settlement
that addresses the issues set forth in the Court’s Order, including, without limitation, a non-reversionary
settlement and a revised class definition. The parties are in the process of memorializing this modified
settlement; and

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WHEREAS, in order to allow the parties to finalize the settlement and obtain all necessary
signatures, the parties request a fifteen (15) day extension of the current deadline in order to finalize the
modified settlement agreement and file a new motion for preliminary approval of class action settlement.

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IT IS THEREFORE STIPULATED AND AGREED that Plaintiff shall file a new motion for
preliminary approval of class action settlement, which addresses the deficiencies set forth in the Court’s
Order, on or before November 14, 2013. The Case Management Conference, which is currently
scheduled to take place on December 4, 2013 at 2:00 P.M., shall be continued until December 18, 2012
at 2:00 P.M., or the next available date this is convenient for the Court.

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IT IS SO STIPULATED.
Respectfully submitted,

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Date: October 29, 2013

NORTH BAY LAW GROUP

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By

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Attorneys for Plaintiffs
DONALD LOUNIBOS

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/s/
David Harris

Date: October 29, 2013

LITTLER MENDELSON, P.C.

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By

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Attorneys for Defendants
KEYPOINT GOVERNMENT SOLUTIONS, INC.

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/s/
Michelle Heverly

[PROPOSED] ORDER
IT IS HEREBY ORDERED AS FOLLOWS:
Plaintiff shall file a new motion for preliminary approval of class action settlement on or before
November 14, 2013. The Case Management Conference, currently scheduled for December 4, 2013,
shall be continued to January 22, 2014, at 2:00 P.M.

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DATED: October 29, 2013

__________________________________
Honorable Jon S. Tigar
United States District Judge

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