Johnson v. LKQ Foster Auto Parts, Inc.

Filing 43

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 9/27/16 ORDERING that Defendant's responsive pleading to Plaintiff's Second Amended Complaint will be due 10/11/2016. (Mena-Sanchez, L)

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Katarzyna W. Nowak [SBN 256977]
FISHER & PHILLIPS LLP
One Embarcadero Center, Suite 2050
San Francisco, California 94111-3712
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Nesheba M. Kittling [ISB 6283261] (Admitted Pro Hac Vice)
FISHER & PHILLIPS, LLP
10 S. Wacker Dr., Suite 3450
Chicago, IL 60606
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Defendant
LKQ FOSTER AUTO PARTS, INC.

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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SHLANDA JOHNSON, on behalf of
herself and all similarly situated
Aggrieved Employees

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Plaintiffs,
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vs.
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LKQ FOSTER AUTO PARTS, INC., a
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Corporation, LKQ CORPORATION, INC., )
a Corporation and DOES 1 through 50,
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inclusive
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Defendants.
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Case No.: 2:15-cv-02413-KJM-AC
JOINT STIPULATION FOR
EXTENSION OF TIME FOR
DEFENDANT TO FILE RESPONSIVE
PLEADING TO PLAINTIFF’S
SECOND AMENDED COMPLAINT;
ORDER
Complaint Filed: 11/19/2015
Trial Date: Not Set

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IT IS HEREBY STIPULATED by and between Plaintiff SHLANDA JOHNSON

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(“Plaintiff”) and Defendant LKQ FOSTER AUTO PARTS, INC. (“Defendant”), by and

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through their counsel, that GOOD CAUSE exists for the Parties’ request that the Court grant

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Defendant a 14 day extension to respond to Plaintiff’s Second Amended Complaint, filed on

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September 12, 2016. Defendant’s responsive 1
pleading will be due October 11, 2016 (or any
JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSIVE PLEADING
TO PLAINTIFF’S SECOND AMENDED COMPLAINT; PROPOSED ORDER

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date the court orders.)
This Stipulation is not being submitted for the purpose of undue delay or for any

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improper purpose and will provide the parties an opportunity to explore the possibility of early

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settlement. In addition, this Stipulation will not impact any existing scheduling dates.

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IT IS SO STIPULATED.

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Dated: September 21, 2016

By: /s/ Katarzyna W. Nowak
FISHER & PHILLIPS LLP
Katarzyna W. Nowak
Counsel for Defendant
LKQ FOSTER AUTO PARTS, INC.,

Dated: September 21, 2016

By: /s/ Barbara E. Figari
THE FIGARI LAW FIRM
Barbara E. Figari
Counsel for Plaintiff
SHLANDA JOHNSON

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JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSIVE PLEADING
TO PLAINTIFF’S SECOND AMENDED COMPLAINT; PROPOSED ORDER

ORDER

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GOOD CAUSE appearing, the Court ORDERS as follows:
Defendant’s responsive pleading to Plaintiff’s Second Amended Complaint will be due
October 11, 2016.
IT IS SO ORDERED.
DATED: September 27, 2016.

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UNITED STATES DISTRICT JUDGE

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JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSIVE PLEADING
TO PLAINTIFF’S SECOND AMENDED COMPLAINT; PROPOSED ORDER