Rickaby et al v. Booz Allen Hamilton, Inc.

Filing 7

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 2/16/2021 CONTINUING the Joint Status Report deadline to 4/26/2021 and RESETTING the Scheduling Conference to 5/10/2021 at 01:30 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Tupolo, A)

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MICHAEL J. NADER SBN Bar No. 200425
[e-mail]
RABIA Z. REED SBN Bar No. 317288
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
500 Capitol Mall, Suite 2500
Sacramento, CA 95814
Telephone: [phone] Fax: [phone]
Attorneys for Defendant
BOOZ-ALLEN HAMILTON, INC.

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PETER F. SAMUEL, SBN 072503
[e-mail]
SAMUEL AND SAMUEL
5050 Sunrise Blvd, Suite C-1
Fair Oaks, CA 95628
Telephone: [phone] Fax: [phone]
GAURAV BOBBY KALRA, SBN 219483
[e-mail]
Gaurav Bobby Kalra, Attorney At Law
177 East Colorado Blvd, Suite 200
Pasadena, CA 91105
Telephone: [phone] Fax: [phone]

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Attorney for Plaintiffs
DYLAN RICKABY, ANDREW RAY
MANYON, JOHN MICHAEL KOELLER,
PATRICK RYAN SEXSON, FRANCISCO
GARCIA, AUSTIN MITCHELL, AND
JERRALIE RENAE ORWIG

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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DYLAN RICKABY, ANDREW RAY
MANYON, JOHN MICHAEL KOELLER,
PATRICK RYAN SEXSON, FRANCISCO
GARCIA, AUSTIN MITCHELL, and
JERRALIE RENAE ORWIG
Plaintiff,

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Case No. 2:20-cv-02190-WBS-CKD
JOINT STIPULATION TO CONTINUE
STATUS CONFERENCE
Date:
Time:
Dept.

March 1, 2021
1:30 pm
5

v.
BOOZ ALLEN HAMILTON, INC., a foreign
corporation,

Complaint Filed: October 31, 2020
Judge:
Hon. William B. Shubb

Defendant.

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Case No. 2:20-cv-00628-JAM-CKD
JOINT STIPULATION TO CONTINUE STATUS CONFERENCE

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs Dylan

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Rickaby, Andrew Ray Manyon, John Michael Koeller, Patrick Ryan Sexson, Francisco Garcia,

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Austin Mitchell, and Jerralie Renae Orwig (“Plaintiffs”) and Defendant Booz Allen Hamilton, Inc.,

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(“Defendant”) (collectively, the “Parties”), by and through their respective attorneys of record, as

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follows:

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WHEREAS, on October 31, 2021, Plaintiffs filed a Complaint for damages in this Court

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alleging a class action against Defendant with the following causes of action (1) Pre-Employment

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Fraud; (2) Violation of Labor Code Section 970; (3) Failure to Pay Overtime Compensation; (4)

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Failure to Furnish Accurate Wage Statements; (5) Unfair Competition; (6) Recission of Contract;

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(7) Failure to Allow Rest Periods; (8) Failure to Allow Meal Periods; and (9) Waiting Time

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Penalties (the “Complaint”);

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WHEREAS, on December 29, 2020, counsel for Defendant contacted Plaintiffs’ counsel to

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arrange acceptance and service of the Complaint and to meet and confer regarding deficiencies in

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Plaintiffs’ pleadings in an effort to avoid motion practice related to the same;

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WHEREAS, on December 29, 2020, counsel for Plaintiffs’ represented that they would be
filing a First Amended Complaint with this court, but it was not filed;
WHEREAS, on February 4, 2021, counsel for Plaintiffs served the Complaint upon
Defendant, without amendment;
WHEREAS, the Parties have met and conferred and agree to continue the initial deadlines
until after Plaintiffs’ counsel files a First Amended Complaint;
WHEREAS, the Parties further agree that that they cannot currently anticipate when

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discovery in this action could begin in earnest, and as such that scheduling discovery deadlines,

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setting a deadline for class certification, setting trial or settlement conferences would be premature

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at this time; and,

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WHEREAS, the Parties agree that it would serve the interests of judicial efficiency to
continue the Parties’ Joint Status Report deadline by at least 60 days.
NOW, THEREFORE, the Parties hereby stipulate and request that the Court:
1. The Court continue the Parties’ Joint Status Report deadline by 60 days from February 12,
2021, to April 13, 2021, or whichever date is most convenient for this Court.
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Case No. 2:20-cv-00628-JAM-CKD
JOINT STIPULATION TO CONTINUE STATUS CONFERENCE

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IT IS SO STIPULATED.
Dated: February 16, 2021

SAMUEL AND SAMUEL

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By: _______________________________________
Peter F. Samuel
Attorneys for Plaintiffs
Dylan Rickaby, Andrew Ray Manyon, John Michael
Koeller, Patrick Ryan Sexson, Francisco Garcia,
Austin Mitchell, and Jerralie Renae Orwig
Dylan Rickaby, Andrew Ray Manyon, John Michael
Koeller, Patrick Ryan Sexson, Francisco Garcia,
Austin Mitchell, and Jerralie Renae Orwig

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Respectfully submitted,

Dated: February 16, 2021

OGLETREE, DEAKINS, NASH, SMOAK, &
STEWART, P.C.
By: __________________________________________
Michael J. Nader
Rabia Z. Reed
Attorneys for Defendant
BOOZ ALLEN HAMILTON, INC

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Case No. 2:20-cv-00628-JAM-CKD
JOINT STIPULATION TO CONTINUE STATUS CONFERENCE

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ORDER
The Court, having read and considered the Parties’ Joint Stipulation filed on February 12,
2020, orders the following:
1. The Court continue the Parties’ Joint Status Report deadline from February 12, 2021, to
April 26, 2021. The Scheduling Conference is reset for May 10, 2021 at 1:30 p.m.

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IT IS SO ORDERED.

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Dated: February 16, 2021

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46008056.2

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20cv2190 Rickaby
- Stip to Cont
Schedg Conf

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[PROPOSED] ORDER

Case No. 2:20-cv-02190-WBS-CKD