Janson et al v. LegalZoom.com, Inc.

Filing 94

Joint MOTION for order Approving Stipulation Joint Motion to Approve Stipulation filed by James T. Wicks on behalf of All Parties. Suggestions in opposition/response due by 4/28/2011 unless otherwise directed by the court. (Wicks, James)

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION
TODD JANSON, et al.,
Plaintiffs,
v.
LEGALZOOM.COM, INC.,
Defendant.

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Case No. 10-04018-CV-C-NKL

JOINT MOTION TO APPROVE STIPULATION
The parties jointly submit the following motion to approve a stipulation between the
parties as to the provision of class contact information:
1.

On April 4, 2010, the Court issued an order in this case partially granting

Plaintiffs’ Motion for Approval of Class Notice and to Direct Defendants to Provide Class
Contact Information. See Doc. 82. The Court set a deadline by which class notice must be
distributed of 45 days from the date of the Order. That date is May 20, 2011.
2.

The Court also read the language “to the present” in the class definition as

running to the date notice is distributed and gave LegalZoom one week from the date of the
Order to produce email and physical addresses for the remainder of class members. The parties
seek the Court’s approval of their agreement to the following procedure for complying with the
Court’s Order.
3.

On Monday, April 4, 2011, as previously agreed between the parties, LegalZoom

produced to Plaintiffs email and physical addresses for class members whose transactions took
place from the beginning of the class period through and including March 1, 2011.

4.

On May 13, 2011, LegalZoom will produce to Plaintiffs the most currently

available email and physical addresses for class members whose transactions take place on and
after March 2, 2011.
5.

As soon as possible after May 20, 2011, LegalZoom will produce to Plaintiffs

email and physical addresses for class members whose transactions take place after the data
produced on May 13, through and including May 20, 2011.
6.

No later than June 6, 2011, Plaintiffs will issue notice to those class members

whose transactions took place following the data produced on May 13, through and including
May 20, 2011.
WHEREFORE, the parties respectfully request that the Court approve the above
stipulated schedule for production of email and physical addresses for members of the class.

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Respectfully submitted,
COOK, VETTER, DOERHOFF &
LANDWEHR, PC

BRYAN CAVE LLP

By: /s/ Matthew A. Clement
Timothy Van Ronzelen
Matthew A. Clement
Kari A. Schulte
231 Madison
Jefferson City, MO 65101

By: /s/ James T. Wicks
Robert M. Thompson MO #38156
James T. Wicks
MO #60409
One Kansas City Place
1200 Main Street, Suite 3500
Kansas City, MO 64105
Tel.: [phone]
Fax: [phone]

David T. Butsch
James J. Simeri
Mathew R. Fields
BUTSCH SIMERI FIELDS LLC
231 South Bemiston Ave., Suite 260
Clayton, MO 63105

Michael G. Biggers MO #24694
James R. Wyrsch
MO #53197
One Metropolitan Square – Suite 3600
211 North Broadway
St. Louis, MO 63102
Tel.: [phone]
Fax: [phone]

Edward D. Robertson, Jr.
Mary Doerhoff Winter
BARTIMUS, FRICKLETON, ROBERTSON
& GORNY
715 Swifts Highway
Jefferson City, MO 65109

ATTORNEYS FOR LEGALZOOM.COM,
INC.

Randall O. Barnes
RANDALL O. BARNES & ASSOCIATES
219 East Dunklin Street, Suite A.
Jefferson City, MO 65101
Steven E. Dyer
10805 Sunset Office Drive, Suite 300
St. Louis, MO 63127
ATTORNEYS FOR PLAINTIFFS

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CERTIFICATE OF SERVICE
I hereby certify that on April 11, 2011, I electronically filed the above and foregoing with
the clerk of court using the CM/ECF system, which will send notice of electronic filing to all
counsel of record.

s/ James T. Wicks

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