Tate-Small et al v. Saks Incorporated et al

Filing 55

ORDER by Judge Suandra Brown Armstrong Granting 54 Stipulation TO EXTEND TIME FOR PARTIES TO FILE A JOINT MOTION FOR SETTLEMENT APPROVAL [LOCAL RULE 6-2]., (ndr, COURT STAFF) (Filed on 12/19/2013)

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H. Tim Hoffman (SBN 49141)
hth@ hlsblaw.com
Chad A. Saunders (SBN 257810)
[e-mail]
Eric Barba (SBN 277932)
ebc@ hlsblaw.com
Hoffman Libenson Saunders & Barba
300 Lakeside Drive, Suite 1000
Oakland, CA 94612
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiffs
MARCIA TATE-SMALL, CASSANDRA THOMAS,
and ROBIN LEDGER-RYAN
Jennifer B. Zargarof (SBN 204382)
[e-mail]
Geoffrey D. DeBoskey (SBN 211557)
[e-mail]
SIDLEY AUSTIN LLP
555 West Fifth Street, Suite 4000
Los Angeles, California 90013
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
SAKS INCORPORATED, SAKS & COMPANY and
SAKS FIFTH AVENUE, INC.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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MARCIA TATE-SMALL, CASSANDRA
THOMAS, and ROBIN LEDGER-RYAN,
individually, and on behalf of all others
similarly situated,

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Plaintiffs,
v.
SAKS INCORPORATED, a Tennessee
corporation, SAKS FIFTH AVENUE, INC., a
Massachusetts corporation, SAKS &
COMPANY, a New York corporation, and
SAKS FIFTH AVENUE OFF FIFTH,

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Defendants.

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Case No. 4:12-cv-03903-SBA
Assigned to: Hon. Saundra Brown Armstrong
STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
PARTIES TO FILE A JOINT MOTION
FOR SETTLEMENT APPROVAL [LOCAL
RULE 6-2]
[Complaint filed: February 8, 2012]

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PARTIES TO FILE A JOINT MOTION
SETTLEMENT APPROVAL

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Pursuant to Local Rule 6-2, counsel for Plaintiffs Marcia Tate-Small, Cassandra Thomas, and

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Robin Ledger-Ryan, opt-in Plaintiffs Melissa Cronin, Antonia Rodriguez and Rebecca Smith

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(collectively, “Plaintiffs”), and counsel for Defendants Saks Incorporated, Saks & Company, and

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Saks Fifth Avenue, Inc. (collectively, “Defendants”) (together with Plaintiffs (“the Parties”),

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stipulate as follows:

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Whereas, on November 19, 2013, the Parties filed a joint notice of settlement;

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Whereas, on November 20, 2013, the Court filed an Order directing the parties to file a joint

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motion for settlement approval no later than December 20, 2013 (see Dkt. 95);
Whereas, the Parties have met and conferred through counsel and agreed that the deadline for

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filing their joint motion for settlement approval should be extended until January 6, 2013, due to

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Plaintiffs’ counsel’s deadline to file an appellate brief also on December 20, 2013; and

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Whereas, there have been no other extensions with respect to this motion and the requested
extension will not affect any other deadlines in this case.

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Now, therefore, the Parties stipulate and respectfully request that the Court order as follows:

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1. The Parties deadline to file a joint motion for settlement approval is extended until

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January 6, 2014.

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IT IS SO STIPULATED.

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DATED: DECEMBER 17, 2013

Hoffman Libenson Saunders & Barba

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By: /s/Chad A. Saunders
Chad A. Saunders
ATTORNEYS FOR PLAINTIFFS

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DATED: DECEMBER 17, 2013

Sidley Austin LLP

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By: /s/Jennifer B. Zargarof
Jennifer B. Zargarof
ATTORNEYS FOR DEFENDANTS

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PARTIES TO FILE A JOINT MOTION
SETTLEMENT APPROVAL

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: _______________
12/19/2013

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Honorable Saundra Brown Armstrong
Judge of the United States District Court

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JOINT NOTICE OF SETTLEMENT; STIPULATION AND [PROPOSED] ORDER RE CASE MANAGEMENT
CONFERENCE AND BRIEFING SCHEDULE FOR SETTLEMENT APPROVAL