4EC Holdings, LLC v. Linebarger Goggan Blair & Sampson, LLP

Filing 60

Order by Hon. Vince Chhabria granting 59 Stipulation to Extend Time to Complete Supplemental Approval Issues to March 6, 2015.(knm, COURT STAFF) (Filed on 2/18/2015)

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Michael L. Charlson (SBN 122125)
[e-mail]
Jessica Mussallem (SBN 237806)
[e-mail]
VINSON & ELKINS LLP
525 Market Street, Suite 2750
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
LINEBARGER GOGGAN BLAIR & SAMPSON LLP,
a Texas limited liability partnership
[Names and Addresses of Additional
Counsel Listed on Signature Pages]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO

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4EC HOLDINGS, LLC, a Delaware limited liability
company,

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Plaintiff,
vs.
LINEBARGER GOGGAN BLAIR & SAMPSON
LLP, a Texas limited liability partnership,

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Case No. 3:14-cv-01944 VC
(Class Action)
STIPULATION TO EXTEND TIME
TO COMPLETE SUPPLEMENTAL
BRIEFING ON SETTLEMENT
APPROVAL ISSUES
Courtroom of the Honorable
Vince Chhabria, Courtroom 4

Defendant.
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The parties, by and through their respective counsel of record and subject to the Court’s
approval, stipulate as follows:
RECITALS
WHEREAS, on December 30, 2014, the parties have entered into a Stipulation of Settlement
(the “Stipulation”) to resolve this matter, subject to Court approval;
WHEREAS, on January 22, 2015, the Court held a hearing (the “January 22 Hearing”) on
whether it should grant preliminary approval to the settlement set forth the Stipulation;
WHEREAS, the Court raised certain questions during the January 22 Hearing and by orders
entered January 23 and 27, 2015, the Court posed certain questions to the parties, asking that the
-1STIP.TO EXTEND TIME TO COMPLETE SUPP. BRIEFING ON SETTLEMENT APPROVAL ISSUES

CASE NO.: 3:14-CV-01944 VC

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parties respond to them in a supplemental brief concerning preliminary settlement approval to be

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filed on or before February 20, 2015;

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WHEREAS, the parties have been discussing the possibility of certain modifications to the

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Stipulation intended to respond to issues raised by the Court at the January 22 Hearing, and

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defendant has been collecting certain data requested by the Court;

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WHEREAS, the parties believe that the Court’s consideration of the proposed settlement

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would be enhanced if the parties first reach final positions on, and to the extent applicable document,

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potential modifications to the Stipulation, and if those issues were incorporated into the

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supplemental brief that the Court has requested; and

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WHEREAS, pre-existing business travel will result in counsel for the parties being out of
town for much of the balance of February, making it more difficult for the parties to confer and con;
THEREFORE, subject to the Court’s approval, the parties agree as follows:

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STIPULATION

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The date by which the parties shall file their joint supplemental brief responding to the

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Court’s questions related to settlement approval is extended two weeks, to and including Friday,

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March 6, 2015.

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SO STIPULATED.
JONATHAN R. BASS (SBN 075779)
[e-mail]
COBLENTZ PATCH DUFFY & BASS LLP
One Ferry Building, Suite 200
San Francisco, California 94111
Telephone: [phone]

DATED: February 13, 2015

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By___/s/ Jonathan R. Bass____________
Jonathan R. Bass

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WILLIAM McGRANE (SBN 057761)
[e-mail]
McGRANE LLP
Four Embarcadero Center, Suite 1400
San Francisco, California 94111
Telephone: [phone]

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-2-

STIP.TO EXTEND TIME TO COMPLETE SUPP. BRIEFING ON SETTLEMENT APPROVAL ISSUES

CASE NO.: 3:14-CV-01944 VC

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MATTHEW J. SHIER (SBN 072638)
[e-mail]
shierkatz RLLP
930 Montgomery Street, 6th Floor
San Francisco, California 94133
Telephone: [phone]

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Attorneys for Plaintiff
4EC HOLDINGS, LLC

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VINSON & ELKINS LLP

DATED: February 13, 2015

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By___/s/ Michael L. Charlson________
Michael L. Charlson

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Attorneys for Defendant
LINEBARGER GOGGAN BLAIR
& SAMPSON LLP

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STIP.TO EXTEND TIME TO COMPLETE SUPP. BRIEFING ON SETTLEMENT APPROVAL ISSUES

CASE NO.: 3:14-CV-01944 VC

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PROPOSED ORDER
Pursuant to the Stipulation of the parties and upon good cause showing, the Court HEREBY

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ORDERS that the date by which the parties shall file their joint supplemental brief responding to the

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Court’s questions related to settlement approval is extended two weeks, to and including Friday,

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March 6, 2015.

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IT IS SO ORDERED.

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February 18, 2015
DATED: __________________

________________________________
Honorable Vince Chhabria
United States District Judge

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US 3298480v.1

-4STIP.TO EXTEND TIME TO COMPLETE SUPP. BRIEFING ON SETTLEMENT APPROVAL ISSUES

CASE NO.: 3:14-CV-01944 VC