Johnson et al v. Soliant Health, Inc.

Filing 9

STIPULATION and ORDER for ARBITRATION signed by Chief District Judge Kimberly J. Mueller on 2/17/21 ORDERING that plaintiff Phillip Johnson's claims shall be submitted to arbitration with the American Arbitration Association pursuant to its employment arbitration rules, and this matter is DISMISSED, without prejudice. CASE CLOSED(Kastilahn, A)

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PATRICK J. CAIN (SBN 105331)
THEODORE H. DOKKO (SBN 263830)
SMITH, GAMBRELL & RUSSELL, LLP
444 South Flower Street Suite 1700
Los Angeles, California 90071
Telephone: [phone]
Facsimile: 213-358-7300
Email: [e-mail]
[e-mail]
Attorneys for Defendants
SOLIANT HEALTH, LLC, and
SOLIANT PHYSICIAN STAFFING, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO

SMITH, GAMBRELL & RUSSELL, LLP

444 SOUTH FLOWER STREET, SUITE 1700
LOS ANGELES, CALIFORNIA 90071
TELEPHONE: [phone]

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PHILLIP JOHNSON, on behalf of
himself and others similarly situated,

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Case No. 2:20-CV-02474-KJM-DB
(San Joaquin County Superior Court
Case No.: STK-CV-VOE-20200004388)

Plaintiff,
vs.
SOLIANT HEALTH, INC.; SOLIANT
PHYSICIAN STAFFING, LLC; and
DOES 1-20, inclusive,

STIPULATION AND ORDER
FOR ARBITRATION

Defendants.

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STIPULATION AND ORDER FOR ARBITRATION
SGR/24194316.1

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STIPULATION
Plaintiff Phillip Johnson, on the one hand, and defendants Soliant Health,

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Inc., and Soliant Physician Staffing, LLC, on the other hand, acting by and through

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their counsel of record, stipulate and agree as follows:

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1.

This matter may be submitted to binding arbitration with the American

Arbitration Association pursuant to its employment arbitration rules.
2.

The parties further stipulate and agree that this action may be dismissed

without prejudice.
3.

Commencing on the date this action was filed in the state court (i.e.,

SMITH, GAMBRELL & RUSSELL, LLP

May 28, 2020), and ending on the date 30 days after the Court enters the dismissal

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444 SOUTH FLOWER STREET, SUITE 1700
LOS ANGELES, CALIFORNIA 90071
TELEPHONE: [phone]

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of this action (the “Tolling Period”), the Parties agree that the applicable statute of

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limitations for the claims identified in this action are tolled. The Parties agree

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during the Tolling Period to toll all statutes of limitations, statutes of

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repose, equitable defenses of laches, and all other time-related bars and defenses

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that may apply to Plaintiff’s claims identified in this action.

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DATED: February 8, 2021

SMITH, GAMBRELL & RUSSELL, LLP

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By:

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DATED: February 8, 2021

/s/ Patrick J. Cain
Patrick J. Cain
Theodore H. Dokko
Attorneys for SOLIANT HEALTH, INC.,
AND SOLIANT PHYSICIAN STAFFING,
LLC

SHAKOURI LAW FIRM

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By:

/s/ Ashkan Shakouri
Ashkan Shakouri
Attorneys for PHILLIP JOHNSON

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STIPULATION AND ORDER FOR ARBITRATION
SGR/24194316.1

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ORDER

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Based on the foregoing stipulation, and good cause appearing therefor,

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plaintiff Phillip Johnson’s claims shall be submitted to arbitration with the

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American Arbitration Association pursuant to its employment arbitration rules, and

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the matter is hereby dismissed, without prejudice. Further, commencing on the date

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this action was filed in the state court (i.e., May 28, 2020), and ending on the date

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30 days after entry of this order (the “Tolling Period”), the applicable statute of

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limitations for the claims identified in this action are tolled, including statutes of

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repose, equitable defenses of laches, and all other time-related bars and defenses

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SMITH, GAMBRELL & RUSSELL, LLP

444 SOUTH FLOWER STREET, SUITE 1700
LOS ANGELES, CALIFORNIA 90071
TELEPHONE: [phone]

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that may apply to Plaintiff’s claims identified in this action.
At Sacramento, California, this 17th day of February 2021.

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STIPULATION AND ORDER FOR ARBITRATION
SGR/24194316.1