Case: 1:16-cv-08655 Document #: 17 Filed: 11/29/16 Page 1 of 3 PageID #:40 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION N.P., individually and on behalf of all others similarly situated, Case No. 1:16-cv-8655 Plaintiff, v. STANDARD INNOVATION (US) CORP., d/b/a WE-VIBE, a Delaware corporation, Defendant. JOINT MOTION FOR A 60-DAY STAY OF PROCEEDINGS Plaintiff N.P. (“Plaintiff”) and Defendant Standard Innovation (US) Corp. (“Standard Innovation”) (collectively “the Parties”), respectfully request a 60-day stay of this litigation, until January 27, 2017. In support of the instant Motion, the Parties jointly state as follows: On November 22, 2016, the Parties attended a full-day mediation before the Honorable Morton Denlow (ret.) of JAMS, Chicago. With Judge Denlow’s assistance and after several arms’ length discussions, the Parties executed a Memorandum of Understanding (“MOU”) regarding agreed terms for settlement of Plaintiff’s claims on behalf of herself and a putative settlement class. The Parties are now in the process of drafting a written Class Action Settlement Agreement and the other necessary documents (e.g., proposed notices), which Plaintiff will formally present to the Court by filing a motion for preliminary approval of the settlement. The 1 Case: 1:16-cv-08655 Document #: 17 Filed: 11/29/16 Page 2 of 3 PageID #:41 Parties anticipate that they will complete and sign the Settlement Agreement within thirty days and that Plaintiff will submit a motion to the Court for preliminary approval shortly thereafter. On September 23, 2016, Standard Innovation moved for an extension of time to answer the Complaint. (ECF No. 6.) On September 28, 2016, the Court granted that motion, making November 7, 2016 Standard Innovation’s deadline for responsive pleadings. (ECF No. 10.) On November 2, 2016, Standard Innovation, with Plaintiff’s agreement, moved for a further extension, on the ground that the Parties were engaged in settlement discussions. (ECF No. 12.) The Court granted that motion on November 3, 2016, setting Standard Innovation’s new deadline for December 7, 2016. In light of the Parties’ successful conclusion of their settlement discussions, and taking into account potential scheduling disruptions that may be caused by the upcoming holidays, the Parties hereby parties request a 60-day stay of this litigation, until January 27, 2016, so that they can prepare the settlement papers and submit them to the Court. WHEREFORE, Plaintiff N.P., individually and on behalf of a putative class, and Defendant Standard Innovation (US) Corp. jointly request that the Court enter an order staying this case, including all deadlines, hearings and conferences, for 60 days. Dated: November 29, 2016 Respectfully submitted: /s/ Eve-Lynn J. Rapp BENJAMIN H. RICHMAN brichman@edelson.com BENJAMIN THOMASSEN bthomassen@edelson.com Edelson PC 350 North LaSalle Street, Suite 1300 Chicago, IL 60654 312.589.6370 (phone) 312.589.6378 (fax) /s/ Nathan T. Newman NATHAN T. NEWMAN nathan.newman@tuckerellis.com Tucker Ellis LLP Willis Tower 233 South Wacker Drive, Suite 6950 Chicago, IL 60606 312.624.6300 (phone) 312.624.6309 (fax) 2 Case: 1:16-cv-08655 Document #: 17 Filed: 11/29/16 Page 3 of 3 PageID #:42 EVE-LYNN J. RAPP erapp@edelson.com 123 Townsend, Suite 100 San Francisco, CA 94107 415.234.5262 (phone) 415.373.9435 (fax) NEIL K. GILMAN ngilman@hunton.com Hunton & Williams LLP 2200 Pennsylvania Avenue, NW Washington, DC 20037 202.955.1500 (phone) 202.862.3629 (fax) Counsel for Plaintiff N.P. THOMAS R. WASKOM twaskom@hunton.com Hunton & Williams LLP Riverfront Plaza, East Tower 951 East Byrd Street Richmond, VA 23219 804.788.8403 (phone) 804.343.4868 (fax) Counsel for Defendant Standard Innovation (US) Corp. CERTIFICATE OF SERVICE I hereby certify that on the 29th day of November, 2016, the foregoing was electronically filed with the Clerk of the Court using the ECF system, which will send notification of such filing to all counsel of record. /s/ Nathan T. Newman 3 87830.000002 EMF_US 63059662v2