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Carlos Campbell, An Individual, On v. Euromarket Designs

June 3, 2011

CARLOS CAMPBELL, AN INDIVIDUAL, ON
BEHALF OF HIMSELF AND ALL OTHERS SIMILARLY SITUATED, 16 PLAINTIFFS,
v.
EUROMARKET DESIGNS, INC. D/B/A CRATE & BARREL, AN ILLINOIS U.S.C. § 1407CORPORATION, DEFENDANT.



The opinion of the court was delivered by: Jeffrey S. White United States District Judge Northern District of California

CLASS ACTION STIPULATION AND [Proposed] ORDER STAYING PROCEEDINGS PENDING DECISION ON DEFENDANT'S MOTION TO TRANSFER CASES PURSUANT TO FOR COORDINATED OR CONSOLIDATED PRETRIAL PROCEEDINGS

Complaint Filed: February 18, 2011

Complaint Served: Not Served Action Removed: March 22, 2011

WHEREAS, on March 22, 2011, Defendant Euromarket Designs, Inc. d/b/a Crate & Barrel ("Crate & Barrel") removed a Complaint filed against it by Plaintiff Carlos Campbell ("Plaintiff") to this Court in the above-captioned case, Campbell v. Crate & Barrel, Case No. 3:11-cv-01368-JSW (N.D. Cal.) ("Campbell");

WHEREAS, the following five related cases have also been filed against Crate & Barrel:

1. Dardarian v. Crate & Barrel, Case No. 3:11-cv-00945-JSW (N.D. Cal.) ("Dardarian")

2. O'Connor v. Crate & Barrel, Case No. 3:11-cv-02140-SC (N.D. Cal.) ("O'Connor")

3. Salmonson v. Crate & Barrel, Case No. 2:11-cv-02446-PSG -PLA (C.D. Cal.) ("Salmonson")

4. Heon v. Crate & Barrel, Case No. 3:11-cv-00769-JLS -BGS (S.D. Cal.) ("Heon")

5. Shughrou v. Crate & Barrel, Case No. 4:11-cv-02325-LB (N.D. Cal.) ("Shughrou");

WHEREAS, plaintiffs in all six of these actions purport to represent a class of California consumers and allege that Crate & Barrel unlawfully requested and recorded personal identification information from customers who purchased goods using credit cards at Crate & Barrel's retail establishments;

WHEREAS, plaintiffs in all six actions allege that this practice violates California Civil Code § 1747.08 (the "Song-Beverly Credit Card Act" or "Act");

WHEREAS, all six actions will require a court to resolve nearly identical factual issues relating to a single common defendant, Crate & Barrel;

WHEREAS, the parties agree that centralization of all six actions for coordinated or consolidated pretrial proceedings is proper under 28 U.S.C. ยง 1407, because 9 they share common factual questions, and also because centralization would be convenient and ...


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