Johnson v. LKQ Foster Auto Parts, Inc.

Filing 49

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 5/9/2017 ORDERING that Plaintiff shall file a master complaint consisting of the claims she asserted in Case No. 2:16-cv-02175-TLN-DB and in Case No. 2:15-cv-02413-KJM-AC, and whi ch the Court consolidated on April 20, 2017 under Case No. 2:15-CV-2413 KJM AC, by May 15, 2017; Defendants shall have 30 days (by or on June 15, 2017), in which to respond to Plaintiff's master complaint; The current trial date set for Septembe r 25, 2017, and all related deadlines, including all pretrial and discovery deadlines, shall be continued for a period of two hundred ten (210) days. The new scheduling for the case will be reflected in an amended scheduling order to issue. (Becknal, R)

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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 Defendants
LKQ FOSTER AUTO PARTS, INC.
LKQ CORPORATION, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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)
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Plaintiffs,
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vs.
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LKQ FOSTER AUTO PARTS, INC., LKQ )
CORPORATION, INC.; and DOES 1-50. )
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Defendants.
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SHLANDA JOHNSON, on behalf of
herself and all similarly situated
Aggrieved Employees

Case No.: 2:15-cv-02413-KJM-AC
Related Action: 2:16-cv-02175-TLN-DB
JOINT STIPULATION AND ORDER
FOR FILING OF MASTER
COMPLAINT, CONTINUANCE OF
TRIAL DATE AND RELATED
DISCOVERY DEADLINES
Complaint Filed: 11/19/2015
Trial Date: September 25, 2017

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IT IS HEREBY STIPULATED by and between Plaintiff SHLANDA JOHNSON

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(“Plaintiff”) and Defendants LKQ FOSTER AUTO PARTS, INC. and LKQ CORPORATION,

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INC. (“Defendants”), that GOOD CAUSE exists for Plaintiff to file a master complaint

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incorporating the claims she asserted in Case No. 2:16-cv-02175-TLN-DB and in Case No. 2:15-

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cv-02413-KJM-AC, and which the Court consolidated on April 20, 2017 under Case No. 2:151

JOINT STIPULATION AND ORDER FOR FILING OF MASTER COMPLAINT,
CONTINUANCE OF TRIAL DATE AND RELATED DISCOVERY DEADLINES

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CV-2413 KJM AC. Plaintiff shall file her master complaint by May 15, 2017, and Defendants

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shall have thirty (30) days (by or on June 15, 2017), in which to respond to Plaintiff’s master

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complaint.

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GOOD CAUSE also exists to continue the current trial date set for September 25, 2017,

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and all related deadlines, including all pretrial and discovery deadlines, for at least two hundred

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ten (210) days, or to a date thereafter that is convenient for the Court.

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IT IS SO STIPULATED.

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Dated: May 2, 2017

By: /s/ Katarzyna W. Nowak
FISHER & PHILLIPS LLP
Nesheba M. Kittling
Katarzyna W. Nowak
Counsel for Defendants
LKQ FOSTER AUTO PARTS, INC.,
LKQ CORPORATION, INC.

Dated: May 2, 2017

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

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JOINT STIPULATION AND ORDER FOR FILING OF MASTER COMPLAINT,
CONTINUANCE OF TRIAL DATE AND RELATED DISCOVERY DEADLINES

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ORDER
GOOD CAUSE appearing, the Court ORDERS as follows:

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IT IS HEREBY ORDERED that Johnson v. LKQ Corporation, Inc., Case No. 2:16-cv-

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02175-TLN-DB and Johnson v. LKQ Foster Auto Parts, Inc., and LKQ Corporation, Inc., Case

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No. 2:15-cv-02413-KJM-AC, consolidated as 2:15-CV-2413 KJM AC, shall adhere to the

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following:

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1) Plaintiff shall file a master complaint consisting of the claims she asserted in Case

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No. 2:16-cv-02175-TLN-DB and in Case No. 2:15-cv-02413-KJM-AC, and which the Court

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consolidated on April 20, 2017 under Case No. 2:15-CV-2413 KJM AC, by May 15, 2017.

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2) Defendants shall have 30 days (by or on June 15, 2017), in which to respond to

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Plaintiff’s master complaint.
3) The current trial date set for September 25, 2017, and all related deadlines, including

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all pretrial and discovery deadlines, shall be continued for a period of two hundred ten (210)

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days. The new scheduling for the case will be reflected in an amended scheduling order to issue.

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IT IS SO ORDERED.
DATED: May 9, 2017.

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UNITED STATES DISTRICT JUDGE

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JOINT STIPULATION AND ORDER FOR FILING OF MASTER COMPLAINT,
CONTINUANCE OF TRIAL DATE AND RELATED DISCOVERY DEADLINES