Filed: Mar. 14, 2013
Latest Update: Mar. 14, 2013
Summary: CORRECTED STIPULATION AND [PROPOSED] ORDER TO AMEND COMPLAINT AND VOLUNTARY DISMISSAL OF CERTAIN CLASS REPRESENTATIVES RICHARD SEEBORG, District Judge. WHEREAS, the indirect purchaser plaintiffs filed a Corrected Second Amended Class Action Complaint on October 18, 2011; WHEREAS, the indirect purchaser plaintiffs have indicated that, due to unforeseen personal circumstances, the following class representatives no longer wish to serve as class representations: Laura Allen, Pradeep Arora, Lucas
Summary: CORRECTED STIPULATION AND [PROPOSED] ORDER TO AMEND COMPLAINT AND VOLUNTARY DISMISSAL OF CERTAIN CLASS REPRESENTATIVES RICHARD SEEBORG, District Judge. WHEREAS, the indirect purchaser plaintiffs filed a Corrected Second Amended Class Action Complaint on October 18, 2011; WHEREAS, the indirect purchaser plaintiffs have indicated that, due to unforeseen personal circumstances, the following class representatives no longer wish to serve as class representations: Laura Allen, Pradeep Arora, Lucas ..
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CORRECTED STIPULATION AND [PROPOSED] ORDER TO AMEND COMPLAINT AND VOLUNTARY DISMISSAL OF CERTAIN CLASS REPRESENTATIVES
RICHARD SEEBORG, District Judge.
WHEREAS, the indirect purchaser plaintiffs filed a Corrected Second Amended Class Action Complaint on October 18, 2011;
WHEREAS, the indirect purchaser plaintiffs have indicated that, due to unforeseen personal circumstances, the following class representatives no longer wish to serve as class representations: Laura Allen, Pradeep Arora, Lucas Bina, Cindy Bozan, Robert Cavalear, Andrew Crosby, Casey Hauser, Mary Jane Garland, David Knight, Debra Knight, Thomas Lewis, Bobbi Milam, Linda Moss, Ramona Ravan, Benjamin Roberts, and Anthony Sterling; and
WHEREAS, defendants will not oppose the substitution of the representatives as indicated in the following chart, reserving all of the legal rights and any defenses defendants may have, including but not limited to any objections to the adequacy of the new proposed class representatives:
Former Class Involved State New Class
Representative(s) Representative(s)
Mary Jane Garland Iowa Jerome Hilscher
Pradeep Arora Hawaii Barney Gooman, Jr.
Laura Allen Kansas Benjamin Murray
Linda Moss Maine Scot Larrabee
Robert Cavalear Massachusetts
Casey Hauser Montana Matthew Hosking
Benjamin Roberts New Hampshire Evan Ravenelle
Thomas Lewis New York Susie Lim
Lucas Bina North Dakota Dion Pacheco
David Knight and Debra Oregon Mike Bishop
Knight
Ramona Ravan South Carolina Kyle Kovalchek
Andrew Crosby Tennessee Kim Wood
Anthony Sterling South Dakota
Cindy Bozan Vermont Gregory Westerkamp
Bobbi Milam West Virginia Brian Ice
WHEREAS, defendants agree to the filing of a third amended complaint by the indirect purchaser plaintiffs, for the purpose of making the above substitutions of proposed class representatives; and
WHEREAS, in exchange for the agreement to the substitution of class representatives, each of the above new class representatives agrees to produce verified interrogatory responses to Defendant Panasonic Corporation's First Set of Interrogatories to Indirect Purchaser Plaintiffs, and to produce all documents in each new class representative's possession responsive to Defendant Toshiba Corporation's First Request for Production of Documents to Indirect Purchaser Plaintiffs within fifteen days of the Court's approval of this stipulation and the filing of an amended complaint;
NOW THEREFORE, IT IS HEREBY STIPULATED by and between the undersigned counsel for the parties as follows:
1. The indirect purchaser plaintiffs will file a third amended complaint, as outlined above;
2. The parties stipulate to the voluntary dismissal without prejudice of the claims of Laura Allen, Pradeep Arora, Lucas Bina, Cindy Bozan, Robert Cavalear, Andrew Crosby, Casey Hauser, Mary Jane Garland, David Knight, Debra Knight, Thomas Lewis, Bobbi Milam, Linda Moss, Ramona Ravan, Benjamin Roberts, and Anthony Sterling; and
3. Each of the new class representatives shall produce verified interrogatory responses to Defendant Panasonic Corporation's First Set of Interrogatories to Indirect Purchaser Plaintiffs, and shall produce all documents in each new class representative's possession which are responsive to Defendant Toshiba Corporation's First Request for Production of Documents to Indirect Purchaser Plaintiffs, within fifteen days of the Court's approval of this stipulation and the filing of the indirect purchaser plaintiffs' third amended complaint.
IT IS SO STIPULATED.
IT IS SO ORDERED.
