Mostajo et al v. Nationwide Mutual Insurance Company

Filing 22

STIPULATION and ORDER signed by District Judge John A. Mendez on 2/13/2018 GRANTING leave to file Second Amended Complaint. (Zignago, K.)

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1 2 3 ROBIN G. WORKMAN, Bar No. 145810 WORKMAN LAW FIRM, P.C. 177 Post Street, Suite 800 San Francisco, CA 94108 Telephone: 415.782.3660 Facsimile: 415.788.1028 4 5 Attorney for Plaintiffs ANTHONY MARC MOSTAJO and ELAINE QUEDENS 6 7 8 9 10 11 12 13 14 JAMES J. OH, IL Bar No. 6196413 (admitted pro hac vice) LITTLER MENDELSON, P.C. 321 North Clark Street, Suite 1000 Chicago, IL 60654 Telephone: 312.372.5520 Facsimile: 312.372.7880 KAI-CHING CHA, Bar No. 218738 MICHAEL J. HUI, Bar No. 273212 LITTLER MENDELSON, P.C. 333 Bush Street, 34th Floor San Francisco, CA 94104 Telephone: 415.433.1940 Facsimile: 415.399.8490 Attorneys for Defendant NATIONWIDE MUTUAL INSURANCE COMPANY 15 UNITED STATES DISTRICT COURT 16 EASTERN DISTRICT OF CALIFORNIA 17 18 ANTHONY MARC MOSTAJO, and ELAINE QUEDENS, on behalf of himself and all others similarly situated, 19 Plaintiffs, Case No. 2:17-CV-00350-JAM-AC STIPULATION AND ORDER GRANTING LEAVE TO FILE SECOND AMENDED COMPLAINT 20 v. 21 22 23 NATIONWIDE MUTUAL INSURANCE COMPANY, and Does 1 through 50, inclusive, Defendants. 24 25 26 27 28 Case No. 2:17-CV-00350-JAM-AC STIPULATION RE 2ND AMD COMPLAINT 1 Plaintiffs Anthony Marc Mostajo (“Mostajo”) and Elaine Quedens (“Quedens”), on behalf of 2 themselves and all others similarly situated, and Defendant Nationwide Mutual Insurance Company 3 (“Nationwide”) (collectively, the “Parties”), through their respective counsel of record and with 4 reference to the following facts, stipulate and agree as follows: 5 6 7 8 WHEREAS, on or about January 9, 2017, Mostajo filed the original Complaint in this action alleging violations of the California Labor Code against Nationwide; WHEREAS, on or about February 14, 2017, Mostajo and Quedens filed their First Amended Complaint alleging violations of the California Labor Code against Nationwide; 9 WHEREAS, since the filing of the First Amended Complaint, the Parties have engaged in 10 significant discovery, exchanging documents and data regarding the parties’ claims and defenses; 11 WHEREAS, the Parties have agreed that Mostajo and Quedens may file a Second Amended 12 Complaint, attached hereto as Exhibit A, for the purpose of adding additional causes of action 13 against Nationwide; 14 15 WHEREAS, the Parties agree that Nationwide shall have thirty (30) days from the date of filing of the Second Amended Complaint to respond to the Second Amended Complaint; 16 NOW, THEREFORE, the Parties hereby stipulate and agree that Mostajo and Quedens may 17 file the [Proposed] Second Amended Complaint against Nationwide which is attached as Exhibit A 18 to this Stipulation. The [Proposed] Second Amended Complaint will be deemed filed and served as 19 of the date the Court signs the Order granting this Stipulation. 20 IT IS SO STIPULATED. 21 22 23 24 25 26 27 28 Case No. 2:17-CV-00350-JAM-AC 2. STIPULATION RE 2ND AMD COMPLAINT 1 Date: February 12, 2018 /s/Robin G. Workman ROBIN G. WORKMAN WORKMAN LAW FIRM, P.C. Attorneys for Plaintiffs ANTHONY MARC MOSTAJO and ELAINE QUEDENS 2 3 4 5 Date: February 12, 2018 6 7 8 /s/Kai-Ching Cha JAMES J. OH KAI-CHING CHA LITTLER MENDELSON, P.C. Attorneys for Defendant NATIONWIDE MUTUAL INSURANCE COMPANY 9 10 IT IS SO ORDERED. 11 Dated: 2/13/2018 /s/ John A. Mendez_______________________ 12 HONORABLE JOHN A. MENDEZ UNITED STATES DISTRICT COURT JUDGE 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. 2:17-CV-00350-JAM-AC 3. STIPULATION RE 2ND AMD COMPLAINT

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