Ahmed v. Beverly Health and Rehabilitation Services, Inc., et al.

Filing 12

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 11/10/16: Plaintiff shall have leave to file her First Amended Class Action and Individual Complaint. Defendants shall have twenty-one (21) days after service of the filed First Amended Class Action and Individual Complaint within which to answer or otherwise plead in response thereto. (Kaminski, H)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 MAYALL HURLEY P.C. ROBERT J. WASSERMAN (SBN: 258538) rwasserman@mayallaw.com WILLIAM J. GORHAM (SBN: 151773) wgorham@mayallaw.com NICHOLAS J. SCARDIGLI (SBN: 249947) nscardigli@mayallaw.com VLADIMIR J. KOZINA (SBN: 284645) vjkozina@mayallaw.com 2453 Grand Canal Boulevard Stockton, California 95207-8253 Telephone: (209) 477-3833 Facsimile: (209) 473-4818 Attorneys for Plaintiff Henna Ahmed JESSICA G. WILSON (SBN: 254366) jessica.wilson@dinsmore.com CHARLES M. ROESCH chuck.roesch@dinsmore.com (pro hac vice) DREW B. MILLAR drew.millar@dinsmore.com (pro hac vice) DINSMORE & SHOHL LLP 655 West Broadway, Suite 840 San Diego, CA 92101 Telephone: (619) 356-3518 Facsimile: (619) 615-2082 Attorneys for Defendants Beverly Health and Rehabilitation Services, Inc. and GGNSC Administrative Services, LLC 18 UNITED STATES DISTRICT COURT 19 EASTERN DISTRICT OF CALIFORNIA 20 21 HENNA AHMED, an individual, Plaintiff, 22 23 vs. 24 Case No.: 2:16-cv-01747-WBS-KJN STIPULATION AND [PROPOSED] ORDER GRANTING LEAVE TO FILE FIRST AMENDED CLASS ACTION AND INDIVIDUAL COMPLAINT BEVERLY HEALTH AND REHABILITATION SERVICES, INC.; GGNSC ADMINISTRATIVE SERVICES, LLC and DOES 1-100, inclusive, 25 26 27 Defendants. 28 Stipulation and [Proposed] Order Granting Plaintiff Leave to File First Amended Class Action and Individual Complaint Page 1 of 3 1 IT IS HEREBY STIPULATED by and between the parties hereto through their counsel of 2 record that Plaintiff Henna Ahmed shall have leave to file the attached First Amended Class Action 3 and Individual Complaint in place of the operative first amended complaint for damages in the 4 above-captioned matter, and that Defendants Beverly Health and Rehabilitation Services, Inc. and 5 GGNSC Administrative Services, LLC shall have twenty-one (21) days after service of the filed 6 First Amended Class Action and Individual Complaint within which to answer or otherwise plead 7 in response thereto. 8 9 DATED: November 9, 2016 10 MAYALL HURLEY P.C. By 11 12 13 14 15 DATED: November 9, 2016 /s/ Robert J. Wasserman ROBERT J. WASSERMAN WILLIAM J. GORHAM III NICHOLAS J. SCARDIGLI VLADIMIR J. KOZINA Attorneys for Plaintiff Henna Ahmend DINSMORE SHOHL LLP 16 17 18 19 20 21 22 23 By /s/ Drew B. Millar JESSICA G. WILSON CHARLES M. ROESCH DREW B. MILLAR Attorneys for Defendants, Beverly Health and Rehabilitation Services, Inc. and GGNSC Administrative Services, LLC All signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing 24 25 26 27 28 Stipulation and [Proposed] Order Granting Plaintiff Leave to File First Amended Class Action and Individual Complaint Page 2 of 3 ORDER 1 2 Pursuant to the Parties’ stipulation, IT IS HEREBY ORDERD that Plaintiff shall have leave 3 to file her First Amended Class Action and Individual Complaint, a copy of which is attached to 4 the stipulation. 5 IT IS FURTHER ORDERED that Defendants shall have twenty-one (21) days after service 6 of the filed First Amended Class Action and Individual Complaint within which to answer or 7 otherwise plead in response thereto. 8 9 10 IT IS SO ORDERED. Dated: November 10, 2016 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stipulation and [Proposed] Order Granting Plaintiff Leave to File First Amended Class Action and Individual Complaint Page 3 of 3

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