Otey v. Crowdflower, Inc. et al

Filing 200

STIPULATION AND ORDER re 199 JOINT STIPULATION WITH PROPOSED ORDER FOR A FURTHER BRIEF TWO-WEEK EXTENSION OF TIME TO FILE NEW MOTION FOR SETTLEMENT APPROVAL filed by Crowdflower, Inc. Signed by Judge Jon S. Tigar on July 25, 2014. (wsn, COURT STAFF) (Filed on 7/25/2014)

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William T. Payne (SBN 90988)
Ellen M. Doyle (Pro Hac Vice)
Edward J. Feinstein (Pro Hac Vice)
FEINSTEIN DOYLE PAYNE
& KRAVEC, LLC
429 Forbes Avenue, 17th Floor
Pittsburgh, PA 15219
412-281-8400 (T), 412-281-1007 (F)
[e-mail]
[e-mail]
[e-mail]

Tracy Thompson (SBN 88173)
[e-mail]
M. Michael Cole (SBN 235538)
[e-mail]
MILLER LAW GROUP
A Professional Corporation
111 Sutter Street, Suite 700
San Francisco, CA 94104
Tel. [phone]
Fax [phone]

Mark A. Potashnick (Pro Hac Vice)
WEINHAUS & POTASHNICK
11500 Olive Blvd., Suite 133
St. Louis, MO 63141
314-997-9150 (T), 314-997-9170 (F)
[e-mail]

Attorneys for Defendants
CROWDFLOWER, INC., LUKAS BIEWALD,
and CHRIS VAN PELT

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M ILLER L AW G ROUP

A P ROF E SSIONAL C ORPORATION
C ALIF ORNIA

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Ira Spiro (SBN 67641)
Jennifer Connor (SBN 241480)
SPIRO LAW CORP.
11377 W. Olympic Blvd., 5th Floor
Los Angeles, CA 89064
310-235-2350 (T), 310-235-2351 (F)
[e-mail]
[e-mail]
Attorneys for Plaintiffs
CHRISTOPHER OTEY, MARY GRETH &
THE CONDITIONALLY CERTIFIED FLSA
COLLECTIVE ACTION CLASS

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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21 CHRISTOPHER OTEY & MARY GRETH, on
behalf of themselves and all others similarly
22 situated,
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Case No.: 3:12-cv-05524-JST/MEJ
JOINT STIPULATION FOR A FURTHER
BRIEF TWO-WEEK EXTENSION OF TIME
TO FILE NEW MOTION FOR SETTLEMENT
APPROVAL AND

Plaintiff,

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25 CROWDFLOWER, INC., LUKAS BIEWALD
AND CHRIS VAN PELT,
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[PROPOSED ORDER]
Complaint filed: October 26, 2012

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Defendant(s).

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JOINT STIP. FOR A FURTHER BRIEF TWO-WEEK EXTENSION OF TIME TO FILE NEW MOT. FOR SETTLEMENT
APPROVAL; [PROPOSED ORDER]
Case No.: 3:12-cv-05524-JST/MEJ

Plaintiffs CHRISTOPHER OTEY and MARY GRETH (“Plaintiffs”) and

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2 Defendants CROWDFLOWER, INC., LUKAS BIEWALD, and CHRIS VAN PELT
3 (“Defendants”), by and through their respective counsel, hereby enter into the following Joint
4 Stipulation for a Further Brief Two-Week Extension of Time to File New Motion for
5 Settlement Approval. Specifically, by and through this Stipulation, the parties request that
6 the Court continue the parties’ deadline for filing a renewed motion for preliminary
7 settlement approval up to and including August 11, 2014.
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STIPULATION

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1.

On April 15, 2014, this Court denied Plaintiff’s Motion for Approval of Proposed

10 Settlement without prejudice. Doc. 195.
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2.

In that Order, the Court permitted the Plaintiffs to file a new motion for

M ILLER L AW G ROUP

A P ROF E SSIONAL C ORPORATION
C ALIF ORNIA

12 settlement approval by July 14. Id.
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3.

On July 11, 2014, the Parties submitted a Joint Stipulation for Brief Two-Week

14 Extension of Time to File New Motion for Settlement Approval and [Proposed] Order, which
15 the Court granted on July 15, 2014. Doc. 198.
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3.

Since that time, the parties have continued to correspond and negotiate

17 regarding terms of a new settlement agreement and submission of a new motion for
18 settlement approval, but the Parties believe they need an additional two weeks to attempt
19 to reach agreement and for Plaintiffs’ counsel to prepare a new motion for settlement
20 approval.
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4.

Such continuance will help facilitate a successful resolution.

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JOINT STIP. FOR A FURTHER BRIEF TWO-WEEK EXTENSION OF TIME TO FILE NEW MOT. FOR SETTLEMENT
APPROVAL; [PROPOSED ORDER]
Case No.: 3:12-cv-05524-JST/MEJ

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WHEREFORE, the parties jointly request that the Court enter the proposed Order

2 below, thereby further continuing the deadlines for filing a new motion for settlement
3 approval.
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Respectfully submitted,

6 Dated: July 24, 2014

WEINHAUS & POTASHNICK

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By:

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/s/ Mark A. Potashnick
Mark Potashnick
Attorneys for Plaintiffs
CHRISTOPHER OTEY, MARY GRETH
and the conditionally FLSA collective
action class

M ILLER L AW G ROUP

A P ROF E SSIONAL C ORPORATION
C ALIF ORNIA

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Dated: July 24, 2014

MILLER LAW GROUP
A Professional Corporation

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By:

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/s/ Tracy Thompson
Tracy Thompson
Attorneys for Defendants
CROWDFLOWER, INC., LUKAS
BIEWALD, and CHRIS VAN PELT

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JOINT STIP. FOR A FURTHER BRIEF TWO-WEEK EXTENSION OF TIME TO FILE NEW MOT. FOR SETTLEMENT
APPROVAL; [PROPOSED ORDER]
Case No.: 3:12-cv-05524-JST/MEJ

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[PROPOSED] ORDER
Good cause appearing therefore, the foregoing Joint Stipulation for a Further

3 Brief Two-Week Extension of Time to File New Motion for Settlement Approval
4 (“Stipulation”) is hereby approved and it is hereby ordered that:
Plaintiffs may file a new motion for settlement approval by August 11, 2014.

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NO

HONORABLE JON S. TIGAR
UNITED STATES DISTRICTiCOURT JUDGE
ga r

ER

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J u d ge J o

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M ILLER L AW G ROUP

RT

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A P ROF E SSIONAL C ORPORATION
C ALIF ORNIA

D
RDERE

OO
IT IS S

R NIA

UNIT
ED

9 Dated: July 25, 2014

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DISTRIC
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PURSUANT TO STIPULATION, IT IS SO ORDERED
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JOINT STIP. FOR A FURTHER BRIEF TWO-WEEK EXTENSION OF TIME TO FILE NEW MOT. FOR SETTLEMENT
APPROVAL; [PROPOSED ORDER]
Case No.: 3:12-cv-05524-JST/MEJ