Mostajo et al v. Nationwide Mutual Ins. Co.

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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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

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Attorney for Plaintiffs
ANTHONY MARC MOSTAJO and
ELAINE QUEDENS

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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

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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ANTHONY MARC MOSTAJO, and ELAINE
QUEDENS, on behalf of himself and all others
similarly situated,

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Plaintiffs,

Case No. 2:17-CV-00350-JAM-AC
STIPULATION AND ORDER
GRANTING LEAVE TO FILE
SECOND AMENDED COMPLAINT

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v.
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NATIONWIDE MUTUAL INSURANCE
COMPANY, and Does 1 through 50, inclusive,
Defendants.

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Case No. 2:17-CV-00350-JAM-AC

STIPULATION RE 2ND AMD COMPLAINT

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Plaintiffs Anthony Marc Mostajo (“Mostajo”) and Elaine Quedens (“Quedens”), on behalf of

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themselves and all others similarly situated, and Defendant Nationwide Mutual Insurance Company

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(“Nationwide”) (collectively, the “Parties”), through their respective counsel of record and with

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reference to the following facts, stipulate and agree as follows:

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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;

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WHEREAS, since the filing of the First Amended Complaint, the Parties have engaged in

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significant discovery, exchanging documents and data regarding the parties’ claims and defenses;

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WHEREAS, the Parties have agreed that Mostajo and Quedens may file a Second Amended

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Complaint, attached hereto as Exhibit A, for the purpose of adding additional causes of action

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against Nationwide;

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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;

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NOW, THEREFORE, the Parties hereby stipulate and agree that Mostajo and Quedens may

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file the [Proposed] Second Amended Complaint against Nationwide which is attached as Exhibit A

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to this Stipulation. The [Proposed] Second Amended Complaint will be deemed filed and served as

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of the date the Court signs the Order granting this Stipulation.

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IT IS SO STIPULATED.

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Case No. 2:17-CV-00350-JAM-AC

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STIPULATION RE 2ND AMD COMPLAINT

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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

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Date: February 12, 2018

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/s/Kai-Ching Cha
JAMES J. OH
KAI-CHING CHA
LITTLER MENDELSON, P.C.
Attorneys for Defendant
NATIONWIDE MUTUAL INSURANCE
COMPANY

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IT IS SO ORDERED.

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Dated: 2/13/2018

/s/ John A. Mendez_______________________

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HONORABLE JOHN A. MENDEZ
UNITED STATES DISTRICT COURT JUDGE

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Case No. 2:17-CV-00350-JAM-AC

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STIPULATION RE 2ND AMD COMPLAINT