Castillo v. ADT, LLC

Filing 41

STIPULATION and ORDER TO FILE SECOND AMENDED COMPLAINT signed by Senior Judge William B. Shubb on 8/16/16. (Mena-Sanchez, L)

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Linda Claxton (SBN 125729)
[e-mail]
Alec Hillbo (SBN 287185)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
400 South Hope Street, Suite 1200
Los Angeles, CA 90071
Telephone:
213.239.9800
Facsimile:
213.239.9045

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Attorneys for Defendant ADT LLC

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Alan Harris (SBN 146079)
[e-mail]
Priya Mohan (SBN 228984)
[e-mail]
HARRIS & RUBLE
655 North Central Avenue, 17th Floor
Glendale, California 91203
Telephone:
323.962.3777
Facsimile:
323.962.3004

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David S. Harris (SBN 215224)
[e-mail]
NORTH BAY LAW GROUP
116 E. Blithedale Avenue, Suite #2
Mill Valley, California 92941-2024
Telephone:
415.388.8788
Facsimile:
415.388.8770

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Attorneys for Plaintiff RICARDO CASTILLO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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RICARDO CASTILLO, individually and on
behalf of all others similarly situated,
Plaintiff,

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Case No. 2:15-cv-00383-WBS-KJN
JOINT STIPULATION TO FILE SECOND
AMENDED COMPLAINT; [PROPOSED]
ORDER

v.
ADT LLC and DOES 1–100, inclusive,
Defendants.

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Case No. 2:15-cv-00383-WBS-KJN
JOINT STIPULATION TO FILE SECOND AMENDED COMPLAINT; [PROPOSED] ORDER

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WHEREAS Defendant ADT LLC (hereinafter, “Defendant”) and Plaintiff Ricardo Castillo

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(hereinafter, “Plaintiff”) (collectively, the “Parties”), have entered into a Joint Stipulation and

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Agreement of Compromise and Settlement of Class Action (“Class Settlement Agreement”)

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resolving the claims in this case;

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WHEREAS, the parties have entered into a long form comprehensive Class Settlement
Agreement, including proposed notices to putative class members;
WHEREAS, Plaintiff is preparing the Motion for Preliminary Approval of Class Action
Settlement which will be filed this month;
WHEREAS, pursuant to the Class Settlement Agreement, the parties have agreed that
Plaintiff may file the Second Amended Complaint, which is attached hereto as Exhibit 1.
WHEREAS, the Parties now stipulate and agree that Plaintiff may file the Second Amended
Complaint, attached hereto as Exhibit 1.
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties.
DATED: August 15, 2016

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By:

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/s/ Linda Claxton (as authorized on 8/15/16)
Linda Claxton
Alec Hillbo

Attorneys for Defendant
ADT LLC

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OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

DATED: August 15, 2016

HARRIS & RUBLE
NORTH BAY LAW GROUP
By: /s/ Alan Harris
Alan Harris
David S. Harris
Attorneys for Plaintiff
RICARDO CASTILLO

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Case No. 2:15-cv-00383-WBS-KJN
JOINT STIPULATION TO FILE SECOND AMENDED COMPLAINT; [PROPOSED] ORDER

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ORDER

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IT IS SO ORDERED:
Dated: August 16, 2016

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Case No. 2:15-cv-00383-WBS-KJN
JOINT STIPULATION TO FILE SECOND AMENDED COMPLAINT; [PROPOSED] ORDER