Parker et al v. Dish Network Corporation et al

Filing 55

STIPULATION AND ORDER TO FILE PRELIMINARY APPROVAL PAPERS re 51 Stipulation filed by Dish Network LLC. Signed by Judge Phyllis J. Hamilton on 11/1/11. (nah, COURT STAFF) (Filed on 11/1/2011)

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RICHARD R. PATCH (State Bar No. 88049)
ZUZANA S. IKELS (State Bar No. 208671)
KATHLEEN F. McCONNELL (State Bar No. 239479)
COBLENTZ, PATCH, DUFFY & BASS LLP
One Ferry Building, Suite 200
San Francisco, California 94111-4213
Telephone: [phone]
Facsimile: 415.989.1663
Email: [e-mail], [e-mail]
[e-mail]

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Attorneys for Defendant
DISH NETWORK L.L.C.

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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NANSEE PARKER and PHONG PHAM, on
behalf of themselves and those similarly situated,

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Plaintiffs,

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v.

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Case No. 4:11-cv-01457-PJH
STIPULATED REQUEST TO EXTEND
TIME TO FILE PRELIMINARY
APPROVAL PAPERS AND [PROPOSED]
ORDER

DISH NETWORK LLC,

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Defendant.

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STIP. TO EXTEND TIME TO FILE PRELIM. APP. PAPERS
CASE NO. 4:11-CV-01457-PJH

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Pursuant to Civil L.R. 6-2, 7-12 and 16-2(d), the parties jointly seek to extend the time to file

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preliminary approval papers set forth in the Court’s October 25, 2011 Order (Docket No. 50) and

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respectfully request that the Court enter the following stipulation, as set forth below.

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WHEREAS, the parties have requested, and the Court has granted, a series of extensions

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allowing the parties to finalize and memorialize a written settlement agreement and prepare papers in

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support of preliminary approval;

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WHEREAS, on October 18, 2011, the parties reported that they had agreement on a formal

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settlement agreement and asked the Court to extend the time to file all settlement papers to October 26,

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2011;

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WHEREAS, on October 25, 2011, the Court granted the parties’ stipulated request;

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WHEREAS, the parties need additional time to resolve one remaining issue and therefore request

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an additional two court days to finalize the settlement papers;
WHEREAS, the parties remain prepared to appear for the preliminary approval hearing on

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November 16, 2011, as scheduled in the Court’s October 25, 2011 Order, or at a later date if preferable

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to the Court.

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IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs and DISH, by and
through the undersigned attorneys for the parties, and subject to the Court’s approval, that:
1. The parties shall finalize and file a Joint Motion For Provisional Certification Of

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Settlement Class And Preliminary Approval Of Class Action Settlement on or before

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October 28, 2011;

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2. The Court shall consider the parties’ Joint Motion For Provisional Certification Of

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Settlement Class And Preliminary Approval Of Class Action Settlement on November

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16, 2011, at 9:00 a.m.

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IT IS SO STIPULATED.

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DATED: October 26, 2011

GIRARD GIBBS LLP

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By:
/s/ Amy M. Zeman
Amy M. Zeman
Attorneys for Plaintiffs Nansee Parker and Phong Pham
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STIP. TO EXTEND TIME TO FILE PRELIM. APP. PAPERS
CASE NO. 4:11-CV-01457-PJH

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DATED: October 26, 2011

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COBLENTZ, PATCH, DUFFY & BASS LLP
By:
/s/ Kathleen F. McConnell
Kathleen F. McConnell
Attorneys for Defendant DISH Network LLC

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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S

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yllis J.
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The Honorable Phyllis J. RED
Hamilton
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UnitedIT IS SO
States District Judge

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11/1/11
DATED: ________________

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STIP. TO EXTEND TIME TO FILE PRELIM. APP. PAPERS
CASE NO. 4:11-CV-01457-PJH