Raya v. AMAZON.COM, LLC et al

Filing 74

JOINT STIPULATION AND ORDER TO CONTINUE HEARING ON MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT. The hearing on plaintiff's Motion for Preliminary Approval of Class Action Settlement is continued to Friday, July 29, 2016, at 9 a.m. Signed by Judge Maxine M. Chesney on July 21, 2016. (mmclc2, COURT STAFF) (Filed on 7/21/2016)

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LAW OFFICES OF SAHAG MAJARIAN II
Sahag Majarian, II, Esq. (SBN 146621)
[e-mail]
18250 Ventura Blvd.
Tarzana, CA 91356
Tel.: [phone]
Fax: [phone]

MORGAN, LEWIS & BOCKIUS LLP
ERIC MECKLEY (SBN 168181)
[e-mail]
THERESA MAK (SBN 211435)
[e-mail]
One Market, Spear Street Tower
San Francisco, CA 94105-1126
Tel.: 1+415.442.1000
Fax: 1+415.442.1001

COHELAN KHOURY & SINGER
Isam C. Khoury (SBN 58759)
[e-mail]
Michael D. Singer (SBN 115301)
[e-mail]
J. Jason Hill (SBN 179630)
[e-mail]
605 C Street, Suite 200
San Diego, California 92101
Tel.: [phone]
Fax: [phone]

RICHARD G. ROSENBLATT, admitted pro
hac vice
[e-mail]
JOSEPH A. NUCCIO, admitted pro hac vice
[e-mail]
502 Carnegie Center
Princeton, NJ 08540-6241
Tel.: 1+609.919.6600
Fax: 1+609.919.6701

Attorneys for Plaintiff SANTIAGO RAYA
on behalf of himself and all others similarly
situated.

Attorneys for Defendants
AMAZON.COM, LLC and
GOLDEN STATE FC, LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA –
SAN FRANCISCO

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SANTIAGO RAYA on behalf of himself and
all others similarly situated,

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Plaintiffs,
v.
AMAZON.COM, LLC, a Delaware Limited
Liability Company; GOLDEN STATE FC,
LLC, a Delaware Limited Liability Company
and, DOES 1 through 10, inclusive,
Defendants.

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CASE NO. 15-CV-02005 MMC
CLASS ACTION
JOINT STIPULATION AND
[PROPOSED] ORDER TO CONTINUE
HEARING ON MOTION FOR
PRELIMINARY APPROVAL OF CLASS
ACTION SETTLEMENT

Complaint filed:
Trial date:

March 18, 2015
None set

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON MOTION FOR
PRELIM APPROVAL OF CLASS ACTION SETTLEMENT
CASE NO. 15-CV-02005 MMC

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Plaintiff SANTIAGO RAYA (“Plaintiff”) and Defendants AMAZON.COM, LLC and

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GOLDEN STATE FC, LLC (collectively “Defendants”), through their respective counsel of record,

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jointly stipulate and respectfully request as follows:
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WHEREAS, the hearing on Plaintiff’s Motion for Preliminary Approval of Class Action

Settlement is currently scheduled for 9 a.m. on July 22, 2016;
2.

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WHEREAS, lead defense counsel Richard G. Rosenblatt, who is the sole counsel

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representing Defendants who was involved in all negotiations through Judge Grewal and, thereby, has

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the most personal and direct knowledge regarding the negotiation of the proposed settlement, resides

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and works in New Jersey;
3.

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WHEREAS, Mr. Rosenblatt had planned to appear at the July 22, 2016 hearing in

4.

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WHEREAS, Mr. Rosenblatt currently is suffering from an upper respiratory illness that

person;

will make it very difficult for him to travel cross country and back;

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THEREFORE, the parties stipulate and respectfully request that the Court continue the

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hearing on Plaintiff’s Motion for Preliminary Approval of Class Action Settlement by one (1) week to

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July 29, 2016 at 9 a.m.

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IT IS SO STIPULATED.

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Dated: July 20, 2016

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LAW OFFICES OF SAHAG MAJARIAN II
COHELAN KHOURY & SINGER
By:

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Attorneys for Plaintiff SANTIAGO RAYA

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/s/ J. Jason Hill
J. Jason Hill

Dated: July 20, 2016

MORGAN, LEWIS & BOCKIUS LLP
By:

/s/ Theresa Mak
Theresa Mak

Attorneys for Defendants AMAZON.COM, LLC
and GOLDEN STATE FC, LLC
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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON MOTION FOR
PRELIM APPROVAL OF CLASS ACTION SETTLEMENT
CASE NO. 15-CV-02005 MMC

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ATTESTATION PURSUANT TO LOCAL RULE 5-1(I)(3)
I, Theresa Mak, am the ECF user whose identification and password are being used to file this
Stipulation. I hereby attest that Plaintiff’s counsel, J. Jason Hill, concurs in this filing.

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/s/ Theresa Mak
Counsel to Defendants AMAZON.COM,
LLC and GOLDEN STATE FC, LLC

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON MOTION FOR
PRELIM APPROVAL OF CLASS ACTION SETTLEMENT
CASE NO. 15-CV-02005 MMC

[PROPOSED] ORDER

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The parties having so stipulated, and GOOD CAUSE APPEARING THEREFORE, IT IS

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HEREBY ORDERED that the hearing on Plaintiff’s Motion for Preliminary Approval of Class

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Action Settlement is continued to Friday, July 29, 2016 at 9 a.m.

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IT IS SO ORDERED.

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Dated: July 21, 2016
HON. MAXINE M. CHESNEY
UNITED STATES DISTRICT JUDGE

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON MOTION FOR
PRELIM APPROVAL OF CLASS ACTION SETTLEMENT
CASE NO. 15-CV-02005 MMC