Stipulation

Cal. Super. - 6th Dist.February 21, 2017

AEGIS LAWFIRM, PC KASHIF HAQUE (State Bar No. 218672) SAMUELA. WONG (State Bar No. 217104) JESSICA L. CAMPBELL(State Bar No. 280626) 3 FAWN F. BEKAM(State Bar No. 307312) 9811 Irvine Center Drive, Suite 100 4 Irvine, CA 92618 Telephone: (949) 379-6250 Facsimile: (949) 379-6251 6 Attorneys for Plaintiffs Shirley Foley and 7 Gondelino DeGuzman 8 David F. Faustman (SBN 81862) Tyreen G. Tomer (SBN 249980) 9 Tiana R. Harding (SBN 299189) FOX ROTHSCHILD LLP 345 California Street, Suite 2200 San Francisco, CA 94104-2670 Telephone: (415) 364-5540 12 Facsimile: (415) 391-4436 E-mail:dfaustmanfoxrothschild.corn 13 ttornerfoxmthschild.corn tse ore foxrothschild.corn 14 ym Attorneys for Defendant QUANTUMGLOBALTECHNOLOGIES, LLC l6 17 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THKCOUNTY OF SANTA CLARA CASE NO. 17CV306595 20 21 SHIRLEY FOLEY, individually and on behalf of all others similarly situated, Plaintiff, Assigned forAllPurposes to: Judge Peter JL Kirwan Dept. 19 22 vs. QUANTUMGLOBAL TECHNOLOGIES, LLC, a limited liabilitycompany; and DOES I through 20, inclusive, CLASS ACTION JOINT STIPULATIONTO CONTINUE CASE MANAGEMENTCONFERENCE 26 27 28 Defendants. Date: March 12, 2019 Time: 10:00 a.m. Dept.: 19 Joint Stipulation to Continue CMC Electronically Filed by Superior Court of CA, County of Santa Clara, on 3/4/2019 3:32 PM Reviewed By: R. Tien Case #17CV306595 Envelope: 2583480 1 Plaintiffs Shirley Foley and Gondelino DeGuzman ( "Plaintiffs") and Defendant Quantum Globa 2 Technologies, LLC ("Defendant" ) (collectively, the "Parties" ), by and through their respective counsel of 3 record, hereby stipulate as follows: STATUS 5 The Parties attended private mediation on October 11, 2018, and have reached a settlement in 6 principle. 7 On or about November 26, 2018, the Parties informed the Court that they had reached a settlement 8 in principle and planned to finalize a long-form settlement agreement and seek Court approval of the 9 settlement within 90 days. In response, the Court continued the case management conference to March 10 12, 2019. 11 The hearing on the Motion for Preliminary Approval is currently scheduled for April 23, 2019 at 12 9:00 a.m. 13 REOUEST FOR CONTINUANCE 14 The Parties are close to Iinalizing the long-form settlement agreement and preparing the 15 preliminary approval papers. Given this status, the Parties request that the Court continue the case 16 management conference to April23, 2019 in conjunction with the hearing on the Motion for Preliminary 17 Approval, or to a later date and time that is most convenient for the Court, 18 DATED: March+,2019 19 20 21 22 DATED: March 4, 2019 23 AEGIS LAWFIRM, PC By: W7k= Fawn F. Bekam Attorneys for Plaintiffs 24 25 26 27 David F. Faustman Tyreen G. Torner Tiana R. Harding Attorneys for Defendant 28 1 Joint Stipulation to Continue CMC CERTIFICATE OF SERVICE I, the undersigned, am employed in the County ofOrange, State ofCalifornia. I am over the age of 18 and not a party to the within action; am employed with Aegis Law Firm PC and my business address is 9811 Irvine Center Drive, Suite 100, Irvine, California 92618. 5 On March 4, 2019, I served the foregoing document entitled: ~ JOINT STIPULATIONTO CONTINUE CASK MANAGEMENTCONFERENCE on all the appearing and/or interested parties in this action by placing the original H a true copy thereof enclosed in sealed envelope(s) addressed as follows: 10 11 12 13 14 15 16 David F. Faustman Tyreen G. Torner Tiana Seymore FOX ROTHSCHILD 345 California Street, Suite 2200 San Francisco, CA 94104-2670 Attorneyfor Defendants: guantunt Global Technologies, LLC (BY MAIL) I am readily familiar with the firm's practice of collection and processing correspondence formailing. Under that practice itwould be deposited with the U.S. Postal Service on that same day with postage thereon fullyprepaid at Irvine, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid ifpostage cancellation date or postage meter date is more than one day after date ofdeposit for mailing this affidavit. (Cal Code Civ. Proc. 5 1013(a); Fed. R. Civ. Proc. 5(a); Fed. R Civ. Proc. 5(c).) 17 18 19 20 21 22 23 (BY OVERNIGHT MAIL)I am personally and readily familiar with the business practice of Aegis Law Firm PC for collection and processing correspondence for overnight delivery, and I caused such document(s) described herein to be deposited for delivery to a facility regularly maintained Federal Express for overnight delivery. (Cal Code Civ. Proc. Ii 1013(c); Fed. 11 Civ. Proc. 5(c).) (BY ELECTRONIC TRANSMISSION) I caused said document(s) to be served via electronic transmission to the addressee(s) listed above on the date below. (Cal. Code Civ. Proc. CI 1010.6(6); Fed. /L Civ. Proc. 5(b)(2)(E); Fed. R Civ. Proc. 5(b)(3).) I declare under penalty ofperjury under the laws of the State of California that the foregoing is true and correct. 24 25 Executed on March 4, 2019, at Irvine, California 26 27 CERTIFICATE OF SERVICE