Mirmalek v. Los Angeles Times Communications LLC

STIPULATION AND [PROPOSED] ORDER EXTENDING SETTLEMENT-RELATED DEADLINES
CASE NO. 3:24-CV-01797-CRB
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BURSOR & FISHER, P.A.
Max S. Roberts (State Bar No. 363482)
1330 Avenue of the Americas, 32nd Floor
New York, NY 10019
Telephone: (646) 837-7150
Facsimile: (212) 989-9163
Email: mroberts@bursor.com
BURSOR & FISHER, P.A.
L. Timothy Fisher (State Bar No. 191626)
1990 North California Blvd., 9th Floor
Walnut Creek, CA 94596
Telephone: (925) 300-4455
Facsimile: (925) 407-2700
E-mail: ltfisher@bursor.com
HUNTON ANDREWS KURTH LLP
Jason J. Kim (State Bar No. 221476)
550 South Hope Street, Suite 2000
Los Angeles, CA 90071
Telephone: (213) 532-200
Facsimile: (213) 532-2020
Email: kimj@HuntonAK.com
Attorney for Defendant Los Angeles
Times Communications, LLC
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
TALIAH MIRMALEK, individually and on
behalf of all others similarly situated,
Plaintiff,
v.
LOS ANGELES TIMES COMMUNICATIONS,
LLC,
Defendant.
Case No. 3:24-cv-01797-CRB
STIPULATION AND [PROPOSED]
ORDER EXTENDING SETTLEMENT-
RELATED DEADLINES
Judge: Hon. Charles R. Breyer
Case 3:24-cv-01797-CRB Document 52 Filed 02/03/26 Page 1 of 5

STIPULATION AND [PROPOSED] ORDER EXTENDING SETTLEMENT-RELATED DEADLINES 	1
CASE NO. 3:24-CV-01797-CRB
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Pursuant to Civil Local Rules 6-2 and 7-11, Plaintiff Taliah Mirmalek (“Plaintiff”) and
Defendant Los Angeles Times Communications, LLC (“Defendant”) (collectively, the “Parties”), by
and through their undersigned counsel, hereby stipulate and agree as follows:
WHEREAS, on July 10, 2025, the Parties filed a Notice of Settlement, which stated that the
Parties will finalize the settlement agreement and file a motion for preliminary approval on or before
August 25, 2025 (ECF No. 37).
WHEREAS, on December 19, 2025, the Court granted the Parties’ the Motion for
Preliminary Approval and set deadlines related to notice and final approval of the settlement. (ECF
No. 50);
WHEREAS, due to unforeseen difficulties and burdens associated with the collection and
compilation of IP addresses to combat the submission of fraudulent online claims, the Parties and
the Settlement Administrator require additional time to carry out the Notice Plan;
IT IS ACCORDINGLY STIPULATED, by and between the undersigned counsel for the
Parties, that:
1. 	The new deadlines will be as follows:
EVENT CURRENT
DEADLINE PROPOSED
DEADLINE
Notice Date 	January 20, 2026 	February 20, 2026
Motion for Attorneys’
Fees, Costs, Expenses, and
Service Award March 6, 2026 	April 6, 2026
Objection and Opt-Out
Deadline March 23, 2026 	April 22, 2026
Claims Deadline 	April 20, 2026 	May 20, 2026
Final Approval Motion
and Response to Any
Objections May 4, 2026 	June 4, 2026
Deadline to Submit
Notices of Appearance at
the Final Approval
Hearing
May 4, 2026 	June 4, 2026
Supplement declaration
(1) stating the number of
claims, requests for
exclusion, and objections
to date and (2) attesting
that Notice was
disseminated consistent
with the Settlement
May 12, 2026 	June 12, 2026
Case 3:24-cv-01797-CRB Document 52 Filed 02/03/26 Page 2 of 5

STIPULATION AND [PROPOSED] ORDER EXTENDING SETTLEMENT-RELATED DEADLINES 	2
CASE NO. 3:24-CV-01797-CRB
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EVENT CURRENT
DEADLINE PROPOSED
DEADLINE
Final Approval Hearing May 22, 2026 at 10:00
a.m. (via Zoom)
June 26, 2026 at
10:00 a.m. (via
Zoom)
Award Issuance Date Begins 14 days after
Effective Date Begins 14 days after
Effective Date
Dated: February 2, 2026 	Respectfully submitted,
BURSOR & FISHER, P.A.
By: /s/ Max S. Roberts
Max S. Roberts (State Bar No. 363482)
1330 Avenue of the Americas, 32nd Floor
New York, NY 10019
Telephone: (646) 837-7150
Facsimile: (212) 989-9163
Email: mroberts@bursor.com
BURSOR & FISHER, P.A.
L. Timothy Fisher (State Bar No. 191626)
1990 North California Blvd., 9th Floor
Walnut Creek, CA 94596
Telephone: (925) 300-4455
Facsimile: (925) 407-2700
E-mail: ltfisher@bursor.com
Attorneys for Plaintiff
Dated: February 2, 2026 	HUNTON ANDREWS KURTH LLP
By: /s/ Jason J. Kim
Jason J. Kim (State Bar No. 221476)
550 South Hope Street, Suite 2000
Los Angeles, California 90071
Telephone: (213) 532-200
Facsimile: (213) 532-2020
Email: kimj@HuntonAK.com
Attorney for Defendant
Case 3:24-cv-01797-CRB Document 52 Filed 02/03/26 Page 3 of 5

STIPULATION AND [PROPOSED] ORDER EXTENDING SETTLEMENT-RELATED DEADLINES 	3
CASE NO. 3:24-CV-01797-CRB
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SIGNATURE ATTESTATION
I am the ECF User whose identification and password are being used to file the foregoing
Stipulation and [Proposed] Order Extending Deadline to File Motion for Preliminary Approval.
Pursuant to L.R 5-1(i)(3) regarding signatures, I, Max S. Roberts, attest that concurrence in the filing
of this document has been obtained
/s/ Max S. Roberts
Max S. Roberts
Case 3:24-cv-01797-CRB Document 52 Filed 02/03/26 Page 4 of 5

STIPULATION AND [PROPOSED] ORDER EXTENDING SETTLEMENT-RELATED DEADLINES 	4
CASE NO. 3:24-CV-01797-CRB
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[PROPOSED] ORDER
Pursuant to the Parties’ Stipulation and [Proposed] Order Extending Notice and Final
Approval Deadlines (the “Stipulation”);
The Stipulation is GRANTED as follows:
1. 	The settlement deadlines are extended as follows:
EVENT CURRENT
DEADLINE PROPOSED
DEADLINE
Notice Date 	January 20, 2026 	February 20, 2026
Motion for Attorneys’
Fees, Costs, Expenses, and
Service Award March 6, 2026 	April 6, 2026
Objection and Opt-Out
Deadline March 23, 2026 	April 22, 2026
Claims Deadline 	April 20, 2026 	May 20, 2026
Final Approval Motion
and Response to Any
Objections May 4, 2026 	June 4, 2026
Deadline to Submit
Notices of Appearance at
the Final Approval
Hearing
May 4, 2026 	June 4, 2026
Supplement declaration
(1) stating the number of
claims, requests for
exclusion, and objections
to date and (2) attesting
that Notice was
disseminated consistent
with the Settlement
May 12, 2026 	June 12, 2026
Final Approval Hearing May 22, 2026 at 10:00
a.m. (via Zoom)
June 26, 2026 at
10:00 a.m. (via
Zoom)
Award Issuance Date Begins 14 days after
Effective Date Begins 14 days after
Effective Date
IT IS SO ORDERED.
Dated: HON. CHARLES R. BREYER
United States District Judge
February 3, 2026
Case 3:24-cv-01797-CRB Document 52 Filed 02/03/26 Page 5 of 5