Giroux v. Essex Property Trust, Inc.

Filing 82

ORDER by Judge Haywood S. Gilliam, Jr. Granting 81 Stipulation Regarding Extension to Deadline for Submission of Stipulated Judgment.(ndrS, COURT STAFF) (Filed on 4/1/2019)

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Joseph E. Addiego III (CA SBN 169522)
John D. Freed (CA SBN 261518)
DAVIS WRIGHT TREMAINE LLP
505 Montgomery Street, Suite 800
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
Attorneys for Defendant
ESSEX PROPERTY TRUST, INC.

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IN THE UNITED STATES DISTRICT COURT

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THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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ANGELE GIROUX,

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Plaintiff,
v.
ESSEX PROPERTY TRUST, INC.,
Defendant.

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STIPULATION RE STIPULATED JUDGMENT DEADLINE

Case No. 16-cv-01722-HSG
STIPULATION AND ORDER
REGARDING EXTENSION TO
DEADLINE FOR SUBMISSION OF
STIPULATED JUDGMENT

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On March 14, 2019, the Court entered its Order Granting Motion for Final Approval of

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Class Action Settlement and Granting Motion for Class Counsel Attorneys’ Fees and Costs (“Final

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Approval Order”), which directed the parties to file a Stipulated Judgment by March 29, 2019.

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On or about March 25, 2019, AllClear, the identity theft protection company that had

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committed to provide the additional identity theft protection contemplated in the settlement

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approved by the Court, informed Essex it had been acquired by Experian and would not provide

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those identity theft protection services. The parties immediately responded, and are negotiating an

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extension of coverage with AllClear and to identify a new service provider of identity theft

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protection upon the expiration of the AllClear coverage.

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In order to give the parties time to complete this process and submit a proposal to the Court

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to address this unanticipated issue, the parties respectfully request that the Court continue the

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March 29, 2019 deadline to submit the Stipulated Judgment for two weeks, until April 12, 2019.

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IT IS SO STIPULATED.

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DATED: April 1, 2019

DAVIS WRIGHT TREMAINE LLP
Joseph E. Addiego III
John D. Freed
By:/s/ Joseph E. Addiego III
Joseph E. Addiego III
Attorneys for Defendant
ESSEX PROPERTY TRUST, INC.
STUTHEIT KALIN LLC
Kyann C. Kalin
By: /s/ Kyann C. Kalin
Kyann C. Kalin
Attorneys for Plaintiff

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STIPULATION RE STIPULATED JUDGMENT DEADLINE

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CERTIFICATION OF CONCURRENCE
Pursuant to L.R. 5-1, I hereby attest that Kyann C. Kalin, counsel for Plaintiff Angele

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Giroux, has provided his concurrence in the electronic filing of the foregoing document entitled

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STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION TO DEADLINE

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FOR SUBMISSION OF STIPULATED JUDGMENT

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/s/ Joseph E. Addiego III
Joseph Addiego III

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STIPULATION RE STIPULATED JUDGMENT DEADLINE

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ORDER

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Presently before the Court is the parties’ Stipulation [and Proposed Order] Regarding

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Extension of the Deadline for Submission of a Stipulated Judgment. The deadline is hereby

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extended until April 12, 2019.

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IT IS SO ORDERED.
Date: April 1, 2019

________________________________
Hon. Haywood S. Gilliam, Jr.
United States District Judge

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STIPULATION RE STIPULATED JUDGMENT DEADLINE