Williams v. U.S. Bank National Association
Filing
83
STIPULATION and ORDER ALLOWING PLAINTIFF TO FILE AMENDED COMPLAINT signed by Judge Lawrence K. Karlton on 11/15/2013. Plaintiff may have leave to file her First Amended Complaint, attached as Exhibit A. (Attachments: # 1 Exhibit A)(Zignago, K.)
1
2
3
4
5
Matthew C. Helland, CA State Bar No. 250451
Helland@nka.com
NICHOLS KASTER, LLP
One Embarcadero Center, Suite 720
San Francisco, CA 94111
Telephone: (415) 277-7235
Facsimile: (415) 277-7238
6
Attorney for Plaintiffs and those similarly situated
7
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
Including Professional Corporations
SAMANTHA D. HARDY, Cal. Bar No. 199125
shardy@sheppardmullin.com
HALI M. ANDERSON, Cal. Bar No. 261816
handerson@sheppardmullin.com
501 West Broadway, 19th Floor
San Diego, California 92101-3598
Telephone:
619.338.6500
Facsimile:
619.234.3815
8
9
10
11
12
13
Attorneys for Defendant
U.S. BANK NATIONAL ASSOCIATION
14
IN THE UNTIED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
15
16
17
KAREN WILLIAMS, individually and on
behalf of all others similarly situated,
Case No. 2:12-cv-01907-LKK-EFB
CLASS ACTION
18
19
20
21
Plaintiff,
vs.
U.S. BANK NATIONAL ASSOCIATION,
Defendant.
JOINT STIPULATION AND ORDER
ALLOWING PLAINTIFF TO FILE
AMENDED COMPLAINT
The Hon. Lawrence K. Karlton
Magistrate Judge Edmund F. Brennan
22
23
24
25
26
27
The parties, by and through their attorneys of record, hereby stipulate and agree as
follows, pursuant to Fed. R. Civ. P. 15(a)(2):
WHEREAS, on July 20, 2012, Plaintiff Karen Williams filed her initial complaint
asserting claims under the Fair Labor Standards Act;
28
-1JOINT STIPULATION ALLOWING PLAINTIFF TO FILE AMENDED COMPLAINT
1
2
WHEREAS, Plaintiff filed her motion for conditional certification of her FLSA claims on
February 25, 2013;
3
4
WHEREAS, on June 20, 2013, the Court granted Plaintiff’s motion for conditional
certification;
5
WHEREAS, Plaintiff distributed judicial notice to the FLSA Collective on July 11, 2013;
6
WHEREAS, additional Plaintiffs filed consent forms to join the case during the opt-in
7
8
9
10
11
period;
WHEREAS, Plaintiff seeks to amend her complaint to add additional opt-in Plaintiffs with
California state law claims;
WHEREAS, the parties met and conferred regarding the filing of the proposed First
Amended Complaint, attached as Exhibit A;
12
WHEREAS, Defendant maintains that the claims in the First Amended Complaint do not
13
have merit, but Defendant is nevertheless willing to allow the filing of the First Amended
14
Complaint;
15
16
17
18
19
WHEREAS, the parties agree that the applicable statutes of limitations will not relate back
to the filing of Plaintiff’s original complaint; and
WHEREAS, the deadline for Plaintiff to amend her complaint and add parties is
November 8, 2013;
WHEREFORE, the parties hereby STIPULATE AND AGREE that Plaintiff may have
20
leave to file her First Amended Complaint, attached as Exhibit A.
21
Dated: November 8, 2013
22
NICHOLS KASTER, LLP
By:
23
/s/Matthew C. Helland
Matthew C. Helland
Attorney for Plaintiff and Others Similarly Situated
24
25
Dated: November 8, 2013
SHEPPARD MULLIN RICHTER & HAMPTON
26
By:
27
28
s/Samantha Hardy (as authorized on 11/8/13)
Samantha Hardy
Attorneys for Defendant
-2JOINT STIPULATION AND [proposed] ORDER ALLOWING PLAINTIFF TO FILE AMENDED COMPLAINT
1
IT IS SO ORDERED.
2
Dated: November 15, 2013.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-3JOINT STIPULATION AND [proposed] ORDER ALLOWING PLAINTIFF TO FILE AMENDED COMPLAINT
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?