Christensen et al v. Apple Inc.

Filing 16

Joint MOTION to Stay Pending Dates and Deadlines and Notice of Resolution of Action by Adam Christensen, William Farrell, Jeffrey Scolnick.(Siprut, Joseph)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
ADAM CHRISTENSEN, JEFFREY
SCOLNICK, and WILLIAM FARRELL on
behalf of themselves and all others similarly
situated,
Plaintiff,
v.
APPLE, INC.,
Defendant.

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Case No. 14-cv-10100
Hon. Douglas P. Woodcock

NOTICE OF RESOLUTION OF ACTION AND
JOINT MOTION FOR STAY OF PENDING DATES AND DEADLINES
Plaintiffs Adam Christensen, Jeffrey Scolnick, and William Farrell and Defendant Apple
Inc., hereby notify the Court that they have reached an agreement to resolve the above-captioned
action. The parties respectfully request that the Court enter an order staying all current dates and
deadlines for thirty (30) days to afford the parties time to memorialize their agreement and to file
a stipulation of dismissal of the case.
In further support of this request, Plaintiffs and Apple state as follows:
1.

Plaintiffs filed their Complaint on January 15, 2014.

2.

Apple answered the Complaint on March 13, 2014.

3.

The parties are required to submit a Joint Status Report to the Court today in

advance of the Initial Scheduling Conference scheduled for May 29, 2014.
4.

Plaintiffs and Apple have reached an agreement to resolve this action and anticipate

that they will be able to file a stipulation of dismissal within the next thirty (30) days.

5.

The parties believe that the requested thirty (30) day stay of all case management

dates and deadlines will conserve the Court’s and the parties’ resources by rendering an Initial
Scheduling Conference unnecessary.
6.

This motion is not made for delay or any other improper purpose.

WHEREFORE, Plaintiffs and Apple respectfully request the Court to issue an order staying
this action until June 18, 2014.

Dated: May 19, 2014

Respectfully submitted,

SIPRUT PC

MORRISON & FOERSTER LLP

By:_/s/ Joseph J. Siprut________

By:_/s/ Purvi G. Patel___________

Joseph J. Siprut*
[e-mail]
Brandon Cavanaugh
[e-mail]

SIPRUT PC
17 North State Street
Suite 1600
Chicago, Illinois 60602
Tel: [phone]
Fax: [phone]
Alexander Shapoval
[e-mail]

SIPRUT PC
1 Winnisimmet Street
Chelsea, MA 02150
Tel: [phone]
Fax: [phone]
* Admitted Pro Hac Vice

Attorneys for Plaintiff and the
Putative Class

David M. Walsh*

[e-mail]

Purvi G. Patel*
[e-mail]
Adam M. Sevell*
[e-mail]
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, CA 90017
Tel: [phone]
Fax: [phone]
Dustin F. Hecker
[e-mail]
POSTERNAK, BLANKSTEIN & LUND
Prudential Tower
800 Boylston Street
Boston, MA 02199-8004
Tel: [phone]
Fax: [phone]
* Admitted Pro Hac Vice

Attorneys for Defendant
Apple Inc.