Filed: Jun. 07, 2016
Latest Update: Jun. 07, 2016
Summary: JOINT STIPULATION TO STAY ALL PRETRIAL AND TRIAL DEADLINES AND FOR A SCHEDULING ORDER FOR PRELIMINARY APPROVAL OF A SETTLEMENT AGREEMENT; AND [ PROPOSED ] ORDER JON S. TIGAR , Judge . JOINT STIPULATION The parties have reached an agreement in principle to settle this case. Pursuant to Local Rule 6-2(a), Plaintiffs and Defendants hereby stipulate and request the Court to enter an order staying the case and all its deadlines pending further order by the Court, and to set a deadline of Au
Summary: JOINT STIPULATION TO STAY ALL PRETRIAL AND TRIAL DEADLINES AND FOR A SCHEDULING ORDER FOR PRELIMINARY APPROVAL OF A SETTLEMENT AGREEMENT; AND [ PROPOSED ] ORDER JON S. TIGAR , Judge . JOINT STIPULATION The parties have reached an agreement in principle to settle this case. Pursuant to Local Rule 6-2(a), Plaintiffs and Defendants hereby stipulate and request the Court to enter an order staying the case and all its deadlines pending further order by the Court, and to set a deadline of Aug..
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JOINT STIPULATION TO STAY ALL PRETRIAL AND TRIAL DEADLINES AND FOR A SCHEDULING ORDER FOR PRELIMINARY APPROVAL OF A SETTLEMENT AGREEMENT; AND [PROPOSED] ORDER
JON S. TIGAR, Judge.
JOINT STIPULATION
The parties have reached an agreement in principle to settle this case. Pursuant to Local Rule 6-2(a), Plaintiffs and Defendants hereby stipulate and request the Court to enter an order staying the case and all its deadlines pending further order by the Court, and to set a deadline of August 4, 2016 by which Plaintiffs may file a motion for preliminary approval of the settlement. In support of this request, the parties state as follows:
1. The parties have reached a proposed classwide settlement of the case after engaging in a day-long mediation facilitated by a JAMS mediator, Jed D. Melnick. While the parties have agreed in principle on the terms of the proposed settlement, there is substantial work yet to be done to reduce those terms to a final written class settlement agreement and to prepare the materials required to initiate the class action settlement approval process pursuant to Federal Rule of Civil Procedure 23(e).
2. The requested stay will permit the parties to focus their efforts, resources, and attention on concluding the settlement process. The stay will also save the parties considerable time and expense of continuing litigation of a case the parties have agreed to settle.
3, Consistent with the local rules, previous time modifications in this case are set forth in the accompanying declaration as is a description of the effect of the requested time modification.
WHEREFORE, Plaintiffs and Defendants jointly request that the Court grant their request for a stay of all pretrial and trial deadlines and for an order providing that Plaintiffs may file a motion for preliminary approval of the settlement on or before August 4,2016.
[PROPOSED] ORDER
The parties' Joint Stipulation to Stay All Pretrial and Trial Deadlines and for a Scheduling Order for Preliminary Approval of a Settlement Agreement is GRANTED. The case and all its deadlines are hereby STAYED with the exception that Plaintiffs shall file their motion for preliminary approval of the settlement agreement on or before August 4, 2016.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
