Moore et al v. Verizon Communications, Inc. et al

Filing 165

STIPULATION AND ORDER re 164 STIPULATION WITH PROPOSED ORDER Continuing Final Approval Hearing and Setting Briefing Schedule filed by Karen Jones, Desiree Moore, Verizon Communications, Inc., Verizon Data Services, Inc., Verizon Servic es Corp., Verizon Corporate Services Group Inc., Verizon Services Group, Verizon Services Organization, Inc., Verizon Services Operations Inc., Verizon Corporate Services Corp., Verizon California, Inc., Set/Reset Deadlines as to 164 STIPULATION WITH PROPOSED ORDER Continuing Final Approval Hearing and Setting Briefing Schedule. Motion Hearing set for 7/16/2003 01:00 PM before Hon. Saundra Brown Armstrong.. Signed by Judge ARMSTRONG on 4/10/13. (lrc, COURT STAFF) (Filed on 4/10/2013)

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HENRY WEISSMANN (SBN 132418)
MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue, Thirty-Fifth
Floor
Los Angeles, CA 90071-1560
Telephone:
[phone]
Facsimile:
[phone]
E-mail: [e-mail];
[e-mail]

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Attorneys for Defendants
VERIZON COMMUNICATIONS INC.,
VERIZON CALIFORNIA INC.,
VERIZON CORPORATE SERVICES
GROUP INC., VERIZON SERVICES
CORP., TELESECTOR RESOURCES
GROUP, INC. d/b/a VERIZON
SERVICES GROUP, VERIZON
SERVICES OPERATIONS INC.,
VERIZON SERVICES ORGANIZATION
INC., VERIZON CORPORATE
SERVICES CORP., and VERIZON
DATA SERVICES, INC.

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JEFFREY F. KELLER (SBN 148005)
KELLER GROVER, LLP
1965 Market Street
San Francisco, California 94103
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for the Plaintiffs and
THE SETTLEMENT CLASS

[Additional Counsel on Signature Page]

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[Additional Counsel on Signature Page]

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IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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DESIREE MOORE and KAREN JONES
individually and on behalf of a class of similarly
situated individuals,

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Plaintiffs,

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vs.

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CASE NO. CV 09-1823 SBA
STIPULATION AND ORDER
CONTINUING FINAL APPROVAL
HEARING AND SETTING
BRIEFING SCHEDULE

VERIZON COMMUNICATIONS INC.,
VERIZON CALIFORNIA INC., VERIZON
CORPORATE SERVICES GROUP INC.,
VERIZON SERVICES CORP., TELESECTOR
RESOURCES GROUP, INC. d/b/a VERIZON
SERVICES GROUP, VERIZON SERVICES
OPERATIONS INC., VERIZON SERVICES
ORGANIZATION INC., VERIZON
CORPORATE SERVICES CORP., VERIZON
DATA SERVICES INC., and DOES 1 through
25,
Defendants.

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STIPULATION AND [PROPOSED] ORDER
CASE NO. CV 09-1823 SBA
20460194.1

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WHEREAS, the parties and amicus curie, Enhanced Services Billing, Inc. (“ESBI”),

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through their respective counsel of record, submit this stipulation and proposed order continuing

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the final approval hearing for the class action settlement in this action and setting a briefing

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schedule for all related filings;

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WHEREAS, the final approval hearing on the class action settlement in this action is
currently set for May 9, 2013;
WHEREAS, in preparing the motion for final approval, it was discovered that, due to a
clerical error, notice was not sent to a small percentage of settlement class members;
WHEREAS, the parties intend to send notice to these settlement class members on or

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before April 15, 2013 and set the deadline for these settlement class members to opt out or object

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for forty-five (45) days later;

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WHEREAS, the parties agree that, subject to Court approval, the final approval hearing

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should be continued so that the Court can consider and rule upon all opt-outs and objections in

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one hearing;

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WHEREAS, the parties and ESBI agree to the following briefing schedule in advance of a
final approval hearing on July 16, 2013:


Final approval motion and response to objections due: June 11, 2013, or 35 days
before any alternative date set for the final approval hearing.



Oppositions to attorneys’ fees motion by defendants and ESBI due: June 11, 2013, or
35 days before any alternative date set for the final approval hearing.



Reply in support of attorneys’ fees motion due: July 2, 2013, or 14 days before any
alternative date set for the final approval hearing.

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NOW THEREFORE, the parties to this action and ESBI, through their respective counsel
of record and subject to Court approval, stipulate to the following:

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IT IS HEREBY STIPULATED that, subject to Court approval, the final approval hearing

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shall be held before this Court at 1:00 p.m. on July 16, 2013 in Courtroom 1 on the fourth floor of

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the United States District Court for the Northern District of California, Oakland Courthouse,

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located at 1301 Clay Street, Oakland, California 94612.

-120460194.1

STIPULATION AND [PROPOSED] ORDER
CASE NO. CV 09-1823 SBA

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IT IS HEREBY FURTHER STIPULATED that, subject to Court approval, the following
briefing schedule shall apply in advance of that hearing:


Final approval motion and response to objections due: June 11, 2013, or 35 days
before any alternative date set for the final approval hearing.

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

Oppositions to attorneys’ fees motion by defendants and ESBI due: June 11, 2013, or
35 days before any alternative date set for the final approval hearing.

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

Reply in support of attorneys’ fees motion due: July 2, 2013, or 14 days before any
alternative date set for the final approval hearing.

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DATED: March 29, 2013

MUNGER, TOLLES & OLSON LLP

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By:

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/s/ Rosemarie T. Ring
ROSEMARIE T. RING

Attorneys for Defendants
VERIZON COMMUNICATIONS INC., VERIZON
CALIFORNIA INC., VERIZON CORPORATE
SERVICES GROUP INC., VERIZON SERVICES
CORP., TELESECTOR RESOURCES GROUP, INC.
d/b/a VERIZON SERVICES GROUP, VERIZON
SERVICES OPERATIONS INC., VERIZON
SERVICES ORGANIZATION INC., VERIZON
CORPORATE SERVICES CORP., and VERIZON
DATA SERVICES INC.

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JACOBS KOLTON, CHTD.

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By:

/s/ John G. Jacobs
JOHN G. JACOBS

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Attorneys for Plaintiffs and
THE SETTLEMENT CLASS

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LEWIS WAGNER, LLP

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By:

/s/ Dina M. Cox
DINA M. COX

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Attorneys for ENHANCED SERVICES BILLING,
INC.

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-220460194.1

STIPULATION AND [PROPOSED] ORDER
CASE NO. CV 09-1823 SBA

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Additional counsel:

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ROSEMARIE T. RING (SBN 220769)
MUNGER, TOLLES & OLSON LLP
560 Mission Street, Twenty-Seventh Floor
San Francisco, CA 94105-2907
Telephone:
[phone]
Facsimile:
[phone]
E-mail: [e-mail]

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Attorneys for Defendants
VERIZON COMMUNICATIONS INC.,
VERIZON CALIFORNIA INC.,
VERIZON CORPORATE SERVICES
GROUP INC., VERIZON SERVICES
CORP., TELESECTOR RESOURCES
GROUP, INC. d/b/a VERIZON
SERVICES GROUP, VERIZON
SERVICES OPERATIONS INC.,
VERIZON SERVICES ORGANIZATION
INC., VERIZON CORPORATE
SERVICES CORP., and VERIZON
DATA SERVICES INC.

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JOHN G. JACOBS (PRO HAC VICE)
BRYAN G. KOLTON (PRO HAC VICE)
JACOBS KOLTON, CHTD.
55 West Monroe Street, Suite 2970
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]
jgjacobs@ jacobskolton.com
bgkolton@ jacobskolton.com
DAVID SCHACHMAN (PRO HAC VICE)
LAW OFFICES OF DAVID SCHACHMAN,
PC
55 West Monroe Street, Suite 2970
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Michael W. Sobol (SBN 194857)
Jahan C. Sagafi (SBN 224887)
LIEFF CABRASER HEIMANN &
BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, California 94111-3339
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs and
THE SETTLEMENT CLASS

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-320460194.1

STIPULATION AND [PROPOSED] ORDER
CASE NO. CV 09-1823 SBA

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PURSUANT TO STIPULATION AND FOR GOOD CAUSE SHOWN, IT IS SO

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ORDERED. The Final Approval Hearing shall be held before this Court at 1:00 p.m. on July 16,

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2013, in Courtroom 1 on the fourth floor of the United States District Court for the Northern

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District of California, Oakland Courthouse, located at 1301 Clay Street, Oakland, California

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94612. The following briefing schedule shall apply in advance of that hearing:

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

Final approval motion and response to objections

Due June 11, 2013

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

Opposition to motion for attorneys’ fees

Due June 11, 2013

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

Reply in support of motion for attorneys’ fees

Due July 2, 2013

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Dated: _4/10/13

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SAUNDRA B. ARMSTRONG
United States District Judge

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-420460194.1

STIPULATION AND [PROPOSED] ORDER
CASE NO. CV 09-1823 SBA

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CERTIFICATION

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I, Rosemarie T. Ring, am the ECF User whose identification and password are being used

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to file this STIPULATION AND [PROPOSED] ORDER CONTINUING FINAL APPROVAL

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HEARING. In compliance with General Order 45.X.B., I hereby attest that John G. Jacobs

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concurred in this filing.

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-520460194.1

STIPULATION AND [PROPOSED] ORDER
CASE NO. CV 09-1823 SBA