Free Order - District Court of California - California

Case 4:07-cv-02828-CW

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SEYFARTH SHAW LLP Diana Tabacopoulos (SBN: 128238) [email protected] 2029 Century Park East, Suite 3300 Los Angeles, California 90067-3063 Telephone: (310) 277-7200 Facsimile: (310) 201-5219 SEYFARTH SHAW LLP Eden E. Anderson (SBN 233464) [email protected] 560 Mission Street, Suite 3100 San Francisco, California 94105 Telephone: (415) 397-2823 Facsimile: (415) 397-8549 Attorneys for Defendant CHARLES SCHWAB & CO., INC. DOSTART CLAPP GORDON & COVENEY James F. Clapp (SBN 145814) 4370 La Jolla Village drive, Suite 970 San Diego, California 92122 Telephone: (858) 623-4200 Facsimile: (858) 623-4299 McINERNEY & JONES Charles A. Jones (SBN 224915) 18124 Wedge Parkway #503 Reno, Nevada 89511 Telephone: (775) 849-3811 Facsimile: (775) 849-3866 Attorneys for Plaintiff LINDA YOUNG UNITED STATES DISTRICT COURT

19 IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA 20 21 22 Plaintiffs, 23 vs. 24 CHARLES SCHWAB & CO., INC., 25 Defendant. 26 27 28 1
Stipulation and [Proposed] Order Continuing Hearing on Motion for Preliminary Approval of Proposed Settlement and Filing Deadline for Same; Case No. C 07-2828 CW

LINDA YOUNG, and MIKE SAFAIE, individually and on behalf of all others similarly situated,

) ) ) ) ) ) ) ) ) ) )

Case No. C 07-2828 CW STIPULATION AND ORDER CONTINUING HEARING ON MOTION FOR PRELIMINARY APPROVAL OF PROPOSED SETTLEMENT AND FILING DEADLINE FOR SAME

Case 4:07-cv-02828-CW

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Plaintiffs Linda Young and Mike Safaie ("Plaintiffs") and Defendant Charles Schwab & Co. ("Defendant") (jointly "the Parties"), by and through their undersigned counsel, enter into the following Stipulation: WHEREAS, the Parties have reached an agreement in principle to settle this action in its entirety. WHEREAS, the Parties are finalizing documents for submittal to the Court in connection with a Motion for Preliminary Approval of a proposed settlement. WHEREAS, the Parties are also attempting to finalize a plan of distribution that would allocate the proceeds of the proposed settlement among the employees of different states. WHEREAS, a hearing on a Motion for Preliminary Approval of a proposed settlement is presently set for February 28, 2008. WHEREAS, pursuant to prior stipulation, the Court previously ordered the Parties to file a Motion for Preliminary Approval of a proposed settlement on or before January 22, 2008. WHEREAS, the Parties continue to collect relevant data in connection with the above mentioned settlement efforts and require additional time to prepare settlement documents for submission to the Court. NOW, THEREFORE, the Parties hereby stipulate to extend the hearing date on a Motion for Preliminary Approval of a proposed settlement to March 13, 2008 at 2:00 p.m. The Parties will file a Motion for Preliminary Approval of a proposed settlement not later than February 7, 2008. IT IS SO STIPULATED. DATED: January 22, 2008 MCINERNEY & JONES

By: /s/ Charles A. Jones Charles A. Jones Attorneys for Plaintiff LINDA YOUNG

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Stipulation and [Proposed] Order Continuing Hearing on Motion for Preliminary Approval of Proposed Settlement and Filing Deadline for Same; Case No. C 07-2828 CW

Case 4:07-cv-02828-CW

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DATED: January 22, 2008

SEYFARTH SHAW LLP

By: /s/ Diana Tabacopoulos Eden E. Anderson Attorneys for Defendant CHARLES SCHWAB & CO., INC. IT IS HERBY ORDERED: 1. p.m. 2. The Parties will file with this Court their Motion for Preliminary Approval not That Motion for Preliminary Approval will be heard on March 13, 2008 at 2:00

later than February 7, 2008.

Dated: 1/23/08

_____________________________ Claudia Wilken U.S. District Court Judge

SF1 28313285.1 / 24400-000085

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Stipulation and [Proposed] Order Continuing Hearing on Motion for Preliminary Approval of Proposed Settlement and Filing Deadline for Same; Case No. C 07-2828 CW