Flint v. UGS Corporation

Filing 37

ORDER re 36 granting STIPULATION Shortening Time in Which to Hear Motion for Preliminary Approval of Class Action Settlement, Approval of Class Notice, and Conditional Certification of Settlement Class. Motion Hearing set for 10/16/2008 02:00 PM.. Signed by Judge Claudia Wilken on 9/26/08. (scc, COURT STAFF) (Filed on 9/26/2008)

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1 2 3 4 5 6 7 8 9 10 S C H U B E R T JONCKHEER KOLBE & KRALOWEC LLP ROBERT C. SCHUBERT S.B.N. 62684 MIRANDA P. KOLBE S.B.N. 214392 DUSTIN L. SCHUBERT S.B.N. 254876 SCHUBERT JONCKHEER KOLBE & KRALOWEC LLP Three Embarcadero Center, Suite 1650 San Francisco, California 94111 Telephone: (415) 788-4220 Counsel for Plaintiff MITCHELL F. BOOMER (SBN 121441) JoANNA L. BROOKS (SBN 182986) DYLAN B. CARP (SBN 196846) JACKSON LEWIS LLP 199 Fremont Street, 10th Floor San Francisco, CA 94105 Telephone 415.394.9400 Facsimile: 415.394.9401 Attorneys for Defendant Siemens Product Lifecycle Management Software Inc. (formerly known as UGS CORP.) IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO/OAKLAND DIVISION VANESSA FLINT, Individually and On Behalf of All Others Similarly Situated, Plaintiff, v. UGS CORPORATION and DOES 1 through 100, inclusive, Defendants. Case No. C-07-4640-CAW STIPULATION AND [PROPOSED] ORDER SHORTENING TIME IN WHICH TO HEAR MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, APPROVAL OF CLASS NOTICE, AND CONDITIONAL CERTIFICATION OF SETTLEMENT CLASS JUDGE: Hon. Claudia A. Wilken 11 Three Embarcadero Center, Suite 1650 San Francisco, CA 94111 (415) 788-4220 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Civil L.R. 6-2 STIPULATION AND [PROPOSED] ORDER SHORTENING TIME IN WHICH TO HEAR MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, APPROVAL OF CLASS NOTICE, AND CONDITIONAL CERTIFICATION OF SETTLEMENT CLASS -1- 1 2 3 4 5 6 7 8 9 10 S C H U B E R T JONCKHEER KOLBE & KRALOWEC LLP Plaintiff Vanessa Flint and defendant Siemens Product Lifecycle Management Software Inc. ("Siemens PLM Software")(formerly UGS Corporation) (together, "Parties"), through their respective counsel, stipulate and agree as follows: 1. A proposed settlement ("the Settlement") of the above-captioned class action has been reached by the Parties. 2. Plaintiff now seeks to move the Court for an order preliminarily approving that Settlement, approving the form and method of class notice, and conditionally certifying a settlement class. 3. Defendant Siemens PLM Software will not oppose Plaintiff's motion for preliminary 11 Three Embarcadero Center, Suite 1650 San Francisco, CA 94111 (415) 788-4220 approval of the Settlement, approval of class notice, and conditional certification of the settlement class. Based on the foregoing, IT IS HEREBY STIPULATED AND AGREED that Plaintiff's Motion for Preliminary Approval of Class Action Settlement, Approval of Class Notice, and Conditional Certification of the Settlement Class shall, with the permission of the Court, be heard on shortened time in the Courtroom of the Honorable Claudia A. Wilken on October 16, 2008, at 2:00 p.m ., or as soon thereafter as the matter may be heard by the Court . DATED: September 24, 2008 SCHUBERT JONCKHEER KOLBE & KRALOWEC LLP By: ___________/s/_______________ MIRANDA P. KOLBE Counsel for Plaintiff 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: September 24, 2008 JACKSON LEWIS LLP By: ___________/s/_______________ JOANNA L. BROOKS Counsel for Defendant STIPULATION AND [PROPOSED] ORDER SHORTENING TIME IN WHICH TO HEAR MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, APPROVAL OF CLASS NOTICE, AND CONDITIONAL CERTIFICATION OF SETTLEMENT CLASS -2- 1 2 3 4 5 6 7 8 9 10 S C H U B E R T JONCKHEER KOLBE & KRALOWEC LLP 26th PURSUANT TO STIPULATION, IT IS SO ORDERED this ________ day of Sept. ___________, 2008. _______________________________ Hon. Claudia A. Wilken United States District Judge 11 Three Embarcadero Center, Suite 1650 San Francisco, CA 94111 (415) 788-4220 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER SHORTENING TIME IN WHICH TO HEAR MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, APPROVAL OF CLASS NOTICE, AND CONDITIONAL CERTIFICATION OF SETTLEMENT CLASS -3-

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