STIPULATION RE EXTENSION OF DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT AND ORDER 23 24
Plaintiff Charles Burden ("Plaintiff") and defendant SelectQuote Insurance Services ("Defendant") hereby enter into this Stipulation re Extension of Deadline for Filing Motion for Preliminary Approval of Class Action Settlement and mutually request the Court to enter an order thereon.
1. On October 9, 2012, at a Mandatory Settlement Conference before Magistrate Judge Ryu, the parties reached agreement on the material terms of a class action settlement (the 4 "Settlement"). 5
2. Pursuant to the Court's order dated October 18, 2012, Plaintiff is required to file a 6 motion for preliminary approval of the Settlement by December 18, 2012. 7
3. Despite their diligent efforts, the parties have not yet finalized formal settlement 8 documents due to unanticipated issues that arose during the drafting process. The parties have 9 resolved those issues and expect a formal settlement to be executed within the next few days. 10
4. The parties mutually request that the deadline for Plaintiff to file his motion for 11 preliminary approval, which Plaintiff intends to notice for hearing on February 12, 2013, be extended 12 to December 24, 2012 13
Dated: December 18, 2012 KARASIK LAW FIRM 14 15 By: /s/ Gregory N. Karasik Gregory N. Karasik 3 16 Attorneys for Plaintiff Dated: December 18, 2012 MORRISON & FOERSTER LLP 18 By: /s/ Karen J. Kubin 17 19 Karen J. Kubin 20 Attorneys for Defendant ORDER
Good cause having been shown, the deadline for Plaintiff to file his motion for preliminary 22 approval of the parties' class action settlement is hereby extended to December 24, 2012. 23 24
United States District Judge
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