Hanson v. Pro Solutions

Filing 82

STIPULATION AND ORDER TO EXTEND CLASS NOTICE DEADLINES AND MOVE FINAL APPROVAL HEARING. Final Approval Hearing previously set for 2/23/2017 Continued to 4/27/2017 01:30 PM. Signed by Judge Richard Seeborg on 12/20/16. (cl, COURT STAFF) (Filed on 12/20/2016) Modified on 12/20/2016 (cl, COURT STAFF).

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JUSTIN T. BERGER (SBN 250346)
[e-mail]
EMANUEL B. TOWNSEND (SBN 305373)
[e-mail]
COTCHETT, PITRE & McCARTHY, LLP
San Francisco Airport Office Center
840 Malcolm Road
Burlingame, California 94010
Telephone:
[phone]
Facsimile:
[phone]
NOAH ZINNER (SBN 247581)
[e-mail]
GINA DI GIUSTO (SBN 293252)
[e-mail]
HOUSING AND ECONOMIC RIGHTS
ADVOCATES
1814 Franklin Street, Suite 1040
Oakland, California 94612
Telephone:
[phone]
Facsimile:
[phone]

STEPHEN H. TURNER
[e-mail]
LEWIS BRISBOIS BISGAARD & SMITH
LLP
221 North Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone:
[phone]
Facsimile:
[phone]

Attorneys for Plaintiff Gena Hanson, Individually
and on Behalf of All Others Similarly Situated

Attorneys for Defendant JQD, LLC d/b/a PRO
SOLUTIONS

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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GENA HANSON, individually and on behalf of
all others similarly situated,
Plaintiff,

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v.

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JQD, LLC, d/b/a PRO SOLUTIONS, a
California corporation;

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Defendant.

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Case No. 4:13-cv-05377-RS
JOINT STIPULATION AND [PROPOSED]
ORDER TO EXTEND CLASS NOTICE
DEADLINES AND MOVE FINAL
APPROVAL HEARING
Courtroom:
Judge:

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Hon. Richard Seeborg

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS NOTICE
DEADLINES AND MOVE FINAL APPROVAL HEARING; Case No. 4:13-cv-05377-RS

WHEREAS, pursuant to the Court’s Order Granting Preliminary Approval of Settlement

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(“Preliminary Approval Order”), Defendant Pro Solutions (Defendant) was required to provide the

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claims administrator with specific data regarding the class members by no later than November 12,

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2016;

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WHEREAS, pursuant to the Court’s Preliminary Approval Order, the claims administrator was
required to mail notice postcards to the class members by no later than November 22, 2016;
WHEREAS, Defendant fulfilled its obligation and provided the claims administrator with the
required class member data on or before November 12, 2016 (“Class Notice Deadline”);

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WHEREAS, the class member data that Defendant provided to the claims administrator was

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larger than anticipated and contained certain data fields that were not self-explanatory, which in turn

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required the claims administrator to dedicate more time and effort than originally anticipated to process

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the data and identify the proper class members for notice;

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WHEREAS, the claims administrator worked diligently with the Parties in an attempt to meet

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the November 22, 2016 Class Notice Deadline but ultimately determined that more time was needed to

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adequately process the data and identify the appropriate class members for notice;

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WHEREAS, due to the unforeseen events described above, the parties now stipulate and

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request that the Court enter an order extending the Class Notice Deadline and all other related

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deadlines;

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NOW, THEREFORE, the Parties hereby STIPULATE that the Court enter an order amending
the Court’s Preliminary Approval Order of October 18, 2016 (Docket No. 80), as follows:
(1) Extending the Class Notice Deadline to thirty (30) days from the date the Court enters an
order approving this STIPULATION;
(2) Extending the deadline for class counsel to file its application for attorney’s fees and
expenses to sixty (60) days from the date the Court enters an order approving this STIPULATION;
(3) Extending the deadline for class members to submit their claims or requests for exclusion to
seventy-five (75) days from the date the Court enters an order approving this STIPULATION;
(4) Extending the deadline for filing the motion in support of final approval to eighty-eight (88)
days from the date the Court enters an order approving this STIPULATION; and
JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS NOTICE
DEADLINES AND MOVE FINAL APPROVAL HEARING; Case No. 4:13-cv-05377-RS

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(5) Moving the final approval hearing date to the first Thursday falling one hundred and

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twenty-three (123) days from the date the Court enters an order approving this STIPULATION.

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Respectfully submitted,

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Dated: December 19, 2016

COTCHETT, PITRE & McCARTHY, LLP
By: /s/ Justin T. Berger
JUSTIN T. BERGER
EMANUEL B. TOWNSEND

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HOUSING AND ECONOMIC RIGHTS ADVOCATES
NOAH ZINNER
GINA DI GIUSTO

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Attorneys for Plaintiff and the Proposed Class

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Dated: December 19, 2016

LEWIS BRISBOIS BISGAARD & SMITH LLP
By: /s/ Stephen H. Turner
STEPHEN H. TURNER

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Attorneys for Defendant JQD, LLC d/b/a
PRO SOLUTIONS

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS NOTICE
DEADLINES AND MOVE FINAL APPROVAL HEARING; Case No. 4:13-cv-05377-RS

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[PROPOSED] ORDER
Pursuant to the STIPULATION of the Parties, it is hereby ordered that the Court’s October 18,

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2016 Order Granting Preliminary Approval of Settlement (“Preliminary Approval Order”) (Docket No.

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80) is amended as follows:

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(1) The Class Notice Deadline shall be thirty (30) days from the date of entry of this order;

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(2) The deadline for class counsel to file its application for attorney’s fees and expenses shall

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be sixty (60) days from the date of entry of this order;
(3) The deadline for class members to submit their claims or requests for exclusion shall be
seventy-five (75) days from the date of entry of this order;
(4) The deadline for filing the motion in support of final approval shall be eighty-eight (88)
days from the date of entry of this order; and

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(5) The final approval hearing shall take place on the first Thursday that falls one hundred and

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twenty-three (123) days from the date of entry of this order. Final Approval Hearing 4/27/2017 at 1:30 p.m.

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In all other respects, the Court’s Preliminary Approval Order remains in full force and effect.

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IT IS SO ORDERED.

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DATED: ______________________________
12/20/16

_________________________________
HON. RICHARD SEEBORG
UNITED STATES DISTRICT COURT

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS NOTICE
DEADLINES AND MOVE FINAL APPROVAL HEARING; Case No. 4:13-cv-05377-RS

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