Torres v. Kwong Yet Lung Co., Inc.

Filing 23

ORDER Granting 22 Stipulation to Continue the Deadline to File Motion for Preliminary Approval of Class Settlement for 14 days. (Second Request) IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the foregoing Stipulation is GRANTED and the deadline to file a Motion for Preliminary Approval of Class Settlement is extended and continued for 14 days, until and including 10/15/2015. Signed by Judge Miranda M. Du on 10/1/15. (Copies have been distributed pursuant to the NEF - PS)

CHANT YEDALIAN, ESQ. (Pro Hac Vice)
1 CHANT & COMPANY
A Professional Law Corporation
2 1010 N. Central Ave.
Glendale, CA 91202
3 Phone: [phone]
Fax: [phone]
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KENNETH M. ROBERTS, ESQ.
5 Nevada State Bar No. 4729
DEMPSEY, ROBERTS & SMITH, LTD.
6 1130 Wigwam Parkway
Henderson, NV 89074
7 Phone: [phone]
Fax: [phone]
8 Attorneys for Plaintiff Cirena Torres
9 DAVID A. CARROLL, ESQ.
Nevada State Bar No. 7643
10 ANTHONY J. DIRAIMONDO, ESQ.
Nevada State Bar No. 10875
11 RICE REUTHER SULLIVAN & CARROLL, LLP
3800 Howard Hughes Parkway, Suite 1200
12 Las Vegas, Nevada 89169
Telephone: [phone]
13 Facsimile: [phone]
14 RACHEL KINGREY, ESQ. (Pro Hac Vice)
GARDERE WYNNE SEWELL LLP
15 1601 Elm Street, Suite 3000
Dallas, Texas 75201
16 Telephone: [phone]
Facsimile: [phone]
17 Attorneys for Kwong Yet Lung Co., Inc.
d/b/a International Marketplace
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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CIRENA TORRES, on behalf of herself and
22 all others similarly situated,
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Case No. 2:14-cv-02223-MMD-PAL

Plaintiffs,

STIPULATION AND [PROPOSED]
ORDER TO CONTINUE THE
DEADLINE TO FILE MOTION FOR
PRELIMINARY APPROVAL OF
CLASS SETTLEMENT FOR 14 DAYS

24 vs.
25 KWONG YET LUNG CO., INC.
d/b/a International Marketplace, and DOES
26 1 through 100, inclusive,
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(SECOND REQUEST)

Defendants.

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Pursuant to Local Rule 6-1, Plaintiff Cirena Torres and Defendant Kwong Yet Lung

2 Co., Inc. d/b/a International Marketplace (hereinafter “International Marketplace”), by and
3 through their respective undersigned counsel, submit this Stipulation and [Proposed] Order
4 To Continue The Deadline To File Motion For Preliminary Approval Of Class Settlement
5 For 14 Days, and Plaintiff and Defendant stipulate, agree, and hereby request as follows:
STIPULATION
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1.

The current deadline to file a motion for preliminary approval of class

8 settlement is today, October 1, 2015. This current deadline was set by the Court pursuant
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to an earlier stipulation by the parties (Dkt. No. 16), which was approved by the Court
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(Dkt. No. 17).
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2.

The parties have prepared and entered into a written and signed class-wide

13 settlement agreement (including proposed notices to the class, claim form, and proposed
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order attached thereto) and a copy of that settlement agreement (including the attachments)

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was filed with the Court earlier today (Dkt. No. 21).
3.

Because the parties have entered into class-wide settlement (and have filed

18 their written and signed settlement agreement with the Court, Dkt. No. 21), the class-wide
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settlement will require the Court's review and approval pursuant to Rule 23(e) of the

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Federal Rules of Civil Procedure.
4.

The parties agree they need a short extension in order to prepare the motion

23 for preliminary approval. Accordingly, the parties respectfully request and stipulate that
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the Court extend the current October 1, 2015 deadline to file a motion for preliminary

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approval of class settlement for 14 days, until and including October 15, 2015.

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1 Dated: October 1, 2015
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Respectfully submitted,
By: /s/ Chant Yedalian, Esq
KENNETH M. ROBERTS, ESQ.
Nevada State Bar No. 4729
DEMPSEY, ROBERTS & SMITH, LTD.
1130 Wigwam Parkway Henderson, NV 89074
Telephone: [phone]
Facsimile: 702.388.2514
Email: [e-mail]
Local Counsel
And
CHANT YEDALIAN, ESQ. (Pro Hac Vice)
CHANT & COMPANY
A Professional Law Corporation
1010 N. Central Ave. Glendale, CA 91202
Telehone: 877.574.7100
Facsimile: 877.574.9411
Email: [e-mail]
Attorneys for Plaintiff
RICE REUTHER SULLIVAN & CARROLL, LLP
By: /s/ Anthony J. DiRaimondo, Esq.
DAVID A. CARROLL, ESQ.
Nevada State Bar No. 7643
ANTHONY J. DIRAIMONDO, ESQ.
Nevada State Bar No. 10875
3800 Howard Hughes Parkway, Suite 1200
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]
GARDERE WYNNE SEWELL LLP

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RACHEL KINGREY, ESQ.
Pro Hac Vice
1601 Elm Street, Suite 3000
Dallas, Texas 75201
Telephone: [phone]
Facsimile: [phone]
Attorneys for Kwong Yet Lung Co., Inc.
d/b/a International Marketplace
ORDER

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Having considered the foregoing Stipulation and finding good cause appearing,
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IT IS HEREBY, ORDERED, ADJUDGED, AND DECREED that the foregoing

2 Stipulation is GRANTED and the deadline to file a motion for preliminary approval of
3 class settlement is extended and continued for a period of 14 days, until and including
4 October 15, 2015.
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IT IS SO ORDERED.

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October 1, 2015
Dated: ___________________

_________________________________
HON. MIRANDA M. DU
United States District Judge

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CERTIFICATE OF SERVICE

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I hereby certify that I electronically filed the foregoing with the Court using the

3 CM/ECF system which will send notification of such filing to the electronic service list for
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this case.
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7 Dated: October 1, 2015

CHANT & COMPANY
A Professional Law Corporation

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By: /S/ Chant Yedalian
_______________________
Chant Yedalian

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