Spradlin v. Kasco Corporation

Filing 13

STIPULATION AND ORDER signed by District Judge Troy L. Nunley on 12/27/2013 GRANTING the plaintiff leave to file a First Amended Complaint; ORDERING the defendant to file a responsive pleading within twenty-one days (21) of the filing of the First Amended Complaint. (Michel, G)

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Rory C. Quintana (SBN 258747)
Hallie B. Albert (SBN 258737)
QUINTANA ALBERT LLP
201 Spear Street, Suite 1100
San Francisco, CA 94105
Telephone: [phone]
Fax: [phone]
[e-mail]

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Attorney for Plaintiff
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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ANTHONY SPRADLIN, an individual,

CASE NO.: 2:13-cv-02260-TLN-AC

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Plaintiff,

STIPULATION FOR LEAVE OF COURT TO
FILE FIRST AMENDED COMPLAINT AND
ORDER

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v.
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KASCO CORPORATION a Delaware
corporation; and DOES 1 through 10,
inclusive,

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Defendants..
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STIPULATION
This Stipulation is made and entered into between Plaintiff Anthony Spradlin (herein

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“Plaintiff”) and Defendant Kasco Corporation (herein “Defendant”), by and through their

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respective counsel, with reference to the following.

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1.

WHEREAS, on October 31, 2013, Plaintiff filed his initial Complaint in the

above-referenced matter with this Court;
2.

WHEREAS, Defendant has requested and been provided two extensions for filing

a responsive pleading;
3.

WHEREAS, Plaintiff’s co-worker Gary Allen wishes to pursue litigation against

Defendant;
4.

WHEREAS, Gary Allen’s issues, claims and causes of action against Defendant

are alleged to be identical to those plead by Plaintiff;
5.

WHEREAS, it is in the interest of judicial economy to litigate Plaintiff and
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Case No. 2:13-cv-02260-TLN-AC

STIPULATION FOR LEAVE OF COURT TO
FILE FIRST AMENDED COMPLAINT AND
ORDER

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Allen’s claims together;

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THEREFORE, IT IS HEREBY STIPULATED by and between the parties hereto,

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through their respective attorneys of record that Plaintiff may file a First Amended Complaint, a

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copy of which is attached hereto.

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IT IS FURTHER STIPULATED that Defendant waives notice and service of the First
Amended Complaint and shall have twenty-one (21) days from the filing the First Amended
Complaint to file a responsive pleading.

Dated: December 26, 2013

QUINTANA ALBERT LLP

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By:___s/Rory C. Quintana_______________
Rory C. Quintana
Attorney for Plaintiff

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Dated: December 26, 2013

BEST BEST & KRIEGER LLP

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By:______/s/ Laura Fowler____________
Laura Fowler
Attorney for Defendant

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Dated: December 26, 2013

ICE MILLER LLP

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By:_____/s/ Paul Sinclair______________
Paul Sinclair
Attorney for Defendant

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Case No. 2:13-cv-02260-TLN-AC

STIPULATION TO FILE FIRST AMENDED
COMPLAINT

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ORDER

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The Court having considered the stipulation of the parties, and good cause appearing

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therefore, orders as follows:
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Plaintiff Anthony Spradlin may file the proposed FIRST AMENDED

COMPLAINT as stipulated above.
IT IS SO ORDERED.

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Dated: December 27, 2013

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Troy L. Nunley
United States District Judge

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Case No. 2:13-cv-02260-TLN-AC

STIPULATION TO FILE FIRST AMENDED
COMPLAINT