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).
1
2
3
4
5
6
7
8
9
10
11
12
13
JUSTIN T. BERGER (SBN 250346)
jberger@cpmlegal.com
EMANUEL B. TOWNSEND (SBN 305373)
etownsend@cpmlegal.com
COTCHETT, PITRE & McCARTHY, LLP
San Francisco Airport Office Center
840 Malcolm Road
Burlingame, California 94010
Telephone:
(650) 697-6000
Facsimile:
(650) 692-3606
NOAH ZINNER (SBN 247581)
nzinner@heraca.org
GINA DI GIUSTO (SBN 293252)
gdigiusto@heraca.org
HOUSING AND ECONOMIC RIGHTS
ADVOCATES
1814 Franklin Street, Suite 1040
Oakland, California 94612
Telephone:
(510) 271-8443
Facsimile:
(510) 280-2548
STEPHEN H. TURNER
Stephen.Turner@lewisbrisbois.com
LEWIS BRISBOIS BISGAARD & SMITH
LLP
221 North Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone:
(213) 250-1800
Facsimile:
(213) 250-7900
Attorneys for Plaintiff Gena Hanson, Individually
and on Behalf of All Others Similarly Situated
Attorneys for Defendant JQD, LLC d/b/a PRO
SOLUTIONS
14
IN THE UNITED STATES DISTRICT COURT
15
FOR THE NORTHERN DISTRICT OF CALIFORNIA
16
17
GENA HANSON, individually and on behalf of
all others similarly situated,
Plaintiff,
18
19
v.
20
JQD, LLC, d/b/a PRO SOLUTIONS, a
California corporation;
21
Defendant.
22
)
)
)
)
)
)
)
)
)
)
)
)
Case No. 4:13-cv-05377-RS
JOINT STIPULATION AND [PROPOSED]
ORDER TO EXTEND CLASS NOTICE
DEADLINES AND MOVE FINAL
APPROVAL HEARING
Courtroom:
Judge:
3
Hon. Richard Seeborg
23
24
25
26
27
28
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
1
2
(“Preliminary Approval Order”), Defendant Pro Solutions (Defendant) was required to provide the
3
claims administrator with specific data regarding the class members by no later than November 12,
4
2016;
5
6
7
8
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”);
9
WHEREAS, the class member data that Defendant provided to the claims administrator was
10
larger than anticipated and contained certain data fields that were not self-explanatory, which in turn
11
required the claims administrator to dedicate more time and effort than originally anticipated to process
12
the data and identify the proper class members for notice;
13
WHEREAS, the claims administrator worked diligently with the Parties in an attempt to meet
14
the November 22, 2016 Class Notice Deadline but ultimately determined that more time was needed to
15
adequately process the data and identify the appropriate class members for notice;
16
WHEREAS, due to the unforeseen events described above, the parties now stipulate and
17
request that the Court enter an order extending the Class Notice Deadline and all other related
18
deadlines;
19
20
21
22
23
24
25
26
27
28
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
1
1
(5) Moving the final approval hearing date to the first Thursday falling one hundred and
2
twenty-three (123) days from the date the Court enters an order approving this STIPULATION.
3
4
Respectfully submitted,
5
6
Dated: December 19, 2016
COTCHETT, PITRE & McCARTHY, LLP
By: /s/ Justin T. Berger
JUSTIN T. BERGER
EMANUEL B. TOWNSEND
7
8
9
HOUSING AND ECONOMIC RIGHTS ADVOCATES
NOAH ZINNER
GINA DI GIUSTO
10
11
Attorneys for Plaintiff and the Proposed Class
12
13
14
15
Dated: December 19, 2016
LEWIS BRISBOIS BISGAARD & SMITH LLP
By: /s/ Stephen H. Turner
STEPHEN H. TURNER
16
17
Attorneys for Defendant JQD, LLC d/b/a
PRO SOLUTIONS
18
19
20
21
22
///
23
///
24
///
25
///
26
27
28
JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS NOTICE
DEADLINES AND MOVE FINAL APPROVAL HEARING; Case No. 4:13-cv-05377-RS
2
1
2
[PROPOSED] ORDER
Pursuant to the STIPULATION of the Parties, it is hereby ordered that the Court’s October 18,
3
2016 Order Granting Preliminary Approval of Settlement (“Preliminary Approval Order”) (Docket No.
4
80) is amended as follows:
5
(1) The Class Notice Deadline shall be thirty (30) days from the date of entry of this order;
6
(2) The deadline for class counsel to file its application for attorney’s fees and expenses shall
7
8
9
10
11
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
12
(5) The final approval hearing shall take place on the first Thursday that falls one hundred and
13
twenty-three (123) days from the date of entry of this order. Final Approval Hearing 4/27/2017 at 1:30 p.m.
14
In all other respects, the Court’s Preliminary Approval Order remains in full force and effect.
15
16
IT IS SO ORDERED.
17
18
19
DATED: ______________________________
12/20/16
_________________________________
HON. RICHARD SEEBORG
UNITED STATES DISTRICT COURT
20
21
22
23
24
25
26
27
28
JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS NOTICE
DEADLINES AND MOVE FINAL APPROVAL HEARING; Case No. 4:13-cv-05377-RS
3
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?