De Santos v. Jaco Oil Company

Filing 24

STIPULATION and ORDER 23 for Plaintiff to File First Amended Complaint and Defendant to File an Answer to First Amended Complaint, signed by Magistrate Judge Jennifer L. Thurston on 4/8/2015. (Hall, S)

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Ross E. Shanberg (SBN 179842)
Shane C. Stafford (SBN 216151)
Aaron A. Bartz (SBN 198722)
SHANBERG, STAFFORD & BARTZ, LLP
19200 Von Karman Avenue, Suite 400
Irvine, California 92612
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff LINDA DE SANTOS
and all others similarly situated

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LINDA DE SANTOS an individual, on
behalf of herself and all others
similarly situated,

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Plaintiff,
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vs.
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JACO OIL COMPANY, a California
corporation; and DOES 1 through 100,
inclusive,

CASE NO. 1:14-CV-00738-JLT
JOINT STIPULATION FOR
PLAINTIFF TO FILE FIRST
AMENDED COMPLAINT AND
FOR DEFENDANT TO FILE AN
ANSWER TO FIRST AMENDED
COMPLAINT; [PROPOSED]
ORDER
(Doc. 23)

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Defendants.
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JOINT STIPULATION FOR PLAINTIFF TO FILE FIRST AMENDED COMPLAINT;
[PROPOSED] ORDER

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Plaintiff, LINDA DE SANTOS and Defendant JACO OIL COMPANY
(“JACO”), by and through their attorneys of record, hereby stipulate as follows:

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Whereas, Plaintiff filed a class action on May 16, 2014, based on
Defendant JACO’s alleged violations of the Fair Credit Reporting Act, 15 U.S.C.
§ 1681, et seq. (“FCRA”), and the Investigative Consumer Reporting Agencies
Act, California Civil Code § 1786, et seq. (“ICRAA”);
Whereas, the parties hereby stipulate, by and between their respective

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attorneys of record, that Plaintiff may file a First Amended Complaint, a copy of
which is attached hereto as Exhibit “A.”
It is further stipulated that the First Amended Complaint shall be deemed

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filed as of the date this Stipulation is approved by the Court, and that Defendants

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will be deemed to have been served on the same date.

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Whereas, the parties further stipulate, by and between their respective

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attorneys of record, that JACO, along with the additional defendants named in the

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First Amended Complaint, may file an Answer to First Amended Complaint, a

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copy of which is attached hereto as Exhibit “B.”
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-2JOINT STIPULATION FOR PLAINTIFF TO FILE FIRST AMENDED COMPLAINT;
[PROPOSED] ORDER

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It is further stipulated that the Answer to First Amended Complaint shall be
deemed filed as of the date this Stipulation is approved by the Court, and that

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Plaintiff will be deemed to have been served on the same date.

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DATED: April 7, 2015

SHANBERG STAFFORD & BARTZ LLP

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By:

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/s/ Shane C. Stafford
SHANE C. STAFFORD
ROSS E. SHANBERG
AARON A. BARTZ
Attorneys for Plaintiff
LINDA DE SANTOS,
and all others similarly situated

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DATED: April 7, 2015

KLEIN, DENATALE, GOLDNER,
COOPER, ROSENLIEB & KIMBALL LLP

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By:

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/s/ Connie M. Parker
David J. Cooper
Connie M. Parker
Attorneys for Defendant
JACO OIL COMPANY

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-3JOINT STIPULATION FOR PLAINTIFF TO FILE FIRST AMENDED COMPLAINT;
[PROPOSED] ORDER

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[PROPOSED] ORDER
Based upon the stipulation of the parties, the Court ORDERS:
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Plaintiff’s may file her First Amended Complaint within two court days;

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Defendants’ Answer to the First Amended Complaint shall be filed no later than

five court days thereafter.

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IT IS SO ORDERED.

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Dated:

April 8, 2015

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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-4JOINT STIPULATION FOR PLAINTIFF TO FILE FIRST AMENDED COMPLAINT;
[PROPOSED] ORDER