Hohenberg v. Ferrero USA, Inc

Filing 103

Joint MOTION to Continue Deadline for Joint Motion for Preliminary Approval by Athena Hohenberg, Laura Rude-Barbato. (Attachments: # 1 Proof of Service)(Weston, Gregory) Modified on 1/3/2012 to correct motion and docket text (ag).

1 THE WESTON FIRM
GREGORY S. WESTON (239944)
2 [e-mail]
3 JACK FITZGERALD (257370)
[e-mail]
4 MELANIE PERSINGER (275423)
[e-mail]
5 COURTLAND CREEKMORE (182018)
[e-mail]
6 1405 Morena Blvd., Suite 201
San Diego, CA 92110
7 Telephone:
[phone]
[phone]
8 Facsimile:

WILSON SONSINI GOODRICH &
ROSATI
Professional Corporation
KEITH E. EGGLETON (159842)
COLLEEN BAL (167637)
DALE R. BISH (235390)
AMIR STEINHART (275037)
650 Page Mill Road
Palo Alto, CA 94304
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant Ferrero

9 LAW OFFICES OF RONALD A.
MARRON, APLC
10 RONALD A. MARRON (175650)
[e-mail]
11 3636 4th Avenue, Suite 202
12 San Diego, California 92103
Telephone:
[phone]
[phone]
13 Facsimile:
14 Class Counsel

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UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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19 IN RE FERRERO LITIGATION

Case No. 3:11-cv-00205-H-CAB
Pleading Type: Class Action
Action Filed: February 01, 2011

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JOINT STIPULATION TO CONTINUE
DEADLINE FOR JOINT MOTION FOR
PRELIMINARY APPROVAL

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Judge: The Hon. Cathy Ann Bencivengo

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In re Ferrero Litigation, Case No. 3:11-CV-00205-H-CAB
JOINT STIPULATION TO CONTINUE DEADLINE TO FILE MOTION FOR PRELIMINARY APPROVAL

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Plaintiffs Athena Hohenberg and Laura Rude-Barbato, jointly with Defendant, hereby

2 stipulate and request the Court that the deadline to file the Joint Motion for Preliminary Approval
3 of Settlement be continued from January 5, 2012 to January 19, 2012.
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The parties previously requested, and the Court granted, a 17-day continuation of the

5 deadline to file the Joint Motion for Preliminary Approval of Settlement. Since then, the parties
6 have substantially finalized the terms of the written agreement but are still completing the
7 proposed plan of notice, which is being coordinated with the pending related action in the District
8 of New Jersey. The parties anticipate completing this process in the coming days and filing
9 preliminary approval with both courts shortly thereafter.
10 IT IS SO STIPULATED.
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THE WESTON FIRM
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Dated: January 2, 2012

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By: /s/ Gregory S. Weston
Gregory S. Weston
Class Counsel
WILSON SONSINI GOODRICH &
ROSATI

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18 Dated: January 2, 2012
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By: /s/ Dale Bish
Dale Bish
Attorney for Defendant FERRERO
U.S.A., INC.

21 DATED: January 2, 2012

Respectfully Submitted,

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/s/ Gregory S. Weston
Gregory S. Weston

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THE WESTON FIRM
GREGORY S. WESTON
JACK FITZGERALD
MELANIE PERSINGER
COURTLAND CREEKMORE
1405 Morena Blvd., Suite 201
San Diego, CA 92109
Telephone:
619 798 2006
Facsimile:
480 247 4553
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In re Ferrero Litigation, Case No. 3:11-CV-00205-H-CAB
JOINT STIPULATION TO CONTINUE DEADLINE TO FILE MOTION FOR PRELIMINARY APPROVAL

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LAW OFFICES OF RONALD A.
MARRON, APLC
RONALD A. MARRON
3636 4th Street, Suite 202
San Diego, CA 92103
Telephone:
619 696 9066
Facsimile:
619 564 6665
Class Counsel

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In re Ferrero Litigation, Case No. 3:11-CV-00205-H-CAB
JOINT STIPULATION TO CONTINUE DEADLINE TO FILE MOTION FOR PRELIMINARY APPROVAL