United States District Court, N.D. California, San Francisco Division
JESSICA LEE, individually and on behalf of a class of similarly situated individuals, Plaintiff,
STONEBRIDGE LIFE INSURANCE COMPANY, a Vermont corporation, and TRIFECTA MARKETING GROUP LLC, a Florida limited liability company, Defendants.
DAN MARMALEFSKY (CA SBN 95477), MORRISON & FOERSTER LLP, Los Angeles, California, TIFFANY CHEUNG (CA SBN 211497), MORRISON & FOERSTER LLP, San Francisco, California, Attorneys for Defendant STONEBRIDGE LIFE INSURANCE COMPANY.
RYAN D. ANDREWS, Attorneys for Plaintiff JESSICA LEE and the class.
LAW OFFFICES OF ALEXANDER SKLAVOS, ALEXANDER E. SKLAVOS, Attorney for Defendant TRIFECTA MARKETING GROUP.
STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY DEADLINES
RICHARD SEEBORG, District Judge.
Plaintiff Jessica Lee, Defendant Stonebridge Life Insurance Company ("Stonebridge"), and Defendant Trifecta Marketing Group, LLC ("Trifecta") (collectively the "Parties"), by and through their respective counsel of record, hereby enter into the following stipulation:
WHEREAS, the Parties have reached a class action settlement in principle that would resolve all of the claims of Plaintiff and the Class against both Stonebridge and Trifecta;
WHEREAS, the Court has approved stipulations between the Parties that stayed all activity in this Action, including all hearings and discovery and motion deadlines, for a total period of approximately 11 weeks to allow the Parties to work on a class action settlement agreement and submit it to the Court for preliminary approval (Docket No. 149);
WHEREAS, on February 4, 2014, the Parties subsequently sought a further brief 9-day extension, through February 13, to finalize the agreement, which was granted by the Court (Docket Nos. 154 & 155);
WHEREAS, the Parties have finalized their Settlement Agreement and Exhibits. However, while some signatures have been received, due to severe weather on the East Coast preventing necessary signatories from traveling to work, there has been a delay in obtaining all required signatures;
WHEREAS, the Parties request one final stay of seven (7) days, until February 20, 2014. The Parties believe a further stay of all case deadlines is warranted to avoid unnecessary litigation expenses and to conserve the resources of both the Parties and the Court;
THEREFORE, subject to the approval of the Court, the Parties agree and stipulate that this Action, including all hearings and discovery and motion deadlines, shall remain stayed through February 20, 2014, by which time Plaintiff shall move for preliminary approval of the class action settlement agreement.
IT IS SO STIPULATED.
PURSUANT TO STIPULATION, IT IS ...