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Amochaev v. Citigroup Global Markets

July 22, 2008

RENEE FASSBENDER AMOCHAEV, DEBORAH ORLANDO, KATHRYN N. VARNER AND IVY SO ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFF,
v.
CITIGROUP GLOBAL MARKETS, INC., D/B/A SMITH BARNEY, DEFENDANT.



The opinion of the court was delivered by: Honorable Phyllis J. Hamilton

STIPULATION AND [PROPOSED] ORDER REGARDING EXPANSION OF PAGE LIMITATIONS FOR FINAL SETTLEMENT APPROVAL PLEADINGS AS MODIFIED

Date: August 13, 2008

STIPULATION

WHEREAS, on July 24, 2008, the Parties shall move for a Final Order approving the settlement reached in this matter, which shall be heard on August 13, 2008.

WHEREAS, Plaintiffs seek to file a Memorandum of Points of Authority in Support of the Parties' Motion for Final Settlement Approval which fully addresses the standards for Settlement approval.

WHEREAS, Defendant may file a Memorandum of Points of Authority in conjunction with Plaintiffs' Memorandum.

WHEREAS, it is in the interests of both the Parties and the Court to ensure that all issues relevant to the Settlement are fully briefed and presented to the Court.

NOW, THEREFORE, IT IS AGREED BETWEEN THE PARTIES AS FOLLOWS:

Plaintiffs shall be permitted to exceed the 25-page limit by not more than 10 additional pages in their Memorandum of Points and Authorities in Support of Plaintiffs' Motion for Final Settlement Approval; and Defendant shall be permitted to exceed the 25-page limit by not more than additional pages in its Memorandum of Points and Authorities in conjunction with Plaintiffs' Memorandum in support of the Plaintiffs' Motion for Final Settlement Approval.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP Date: July 18, 2008 By: Kelly M. Dermody Kelly M. Dermody Kelly M. Dermody (State Bar No. 171716) Heather H. Wong (State Bar No. 238546) LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP Embarcadero Center West 275 Battery Street, 30th Floor San Francisco, CA 94111-3339 Telephone: (415) 956-1000 Facsimile: (415) 956-1008 Elizabeth A. Alexander (Pro Hac Vice) LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP 150 Fourth Avenue, N., Ste. 1650 13 Nashville, TN 37219-2423 Telephone: (615) 313-9000 Facsimile: (615) 313-9965 Adam T. Klein (Pro Hac Vice)

Respectfully submitted, Justin M. Swartz (Pro Hac Vice) Piper Hoffman (Pro Hac Vice) OUTTEN & GOLDEN LLP 3 Park Avenue, 29th Floor New York, New York 10016 Telephone: (212) 245-1000 Facsimile: (212) 977-4005

Cyrus Mehri (Pro Hac Vice) Anna M. Pohl (Pro Hac Vice) MEHRI & SKALET, PLLC 1250 Connecticut Ave, NW, Suite 300 Washington, DC 20036 Telephone: (202) 822-5100 Facsimile: (202) 822-4997

James M. Finberg (State Bar No. 114850) ALTSHULER BERZON 177 Post Street, Ste. 300 San Francisco, CA 94108 Telephone: (415) 421-7151 Facsimile: (415) 362-8064 27 ...


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