White v. Cortech West Staffing, LLC et al

Filing 20

STIPULATION and ORDER signed by Senior District Judge William B. Shubb on 07/02/2024 CONTINUING the Rule 26(f) Scheduling Conference to 1/27/2025 at 01:30 PM in Courtroom 5 (WBS) before Senior District Judge William B. Shubb.The Parties will participate in early meeting, and the Joint Rule 26(f) Report shall be filed by 01/13/2025. (Lopez, K)

Download PDF
1 2 3 4 5 6 CHAD D. GREESON, Bar No. 251928 NICHOLAS GIOIELLO, Bar No. 318418 LITTLER MENDELSON, P.C. Treat Towers, Suite 600 1255 Treat Blvd. Walnut Creek, CA 94597 Telephone: (925) 932-2468 Email: cgreeson@littler.com ngioiello@littler.com 7 Attorneys for Defendants THYSSENKRUPP SUPPLY CHAIN SERVICES NA, INC. and THYSSENKRUPP MATERIALS NA, INC. 8 (Additional Counsel Listed on Following Page) 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 CURTIS WHITE, on behalf of himself and all similarly aggrieved employees, CASE NO. 2-22-CV-02270-WBS-AC 13 Plaintiff, 14 JOINT STIPULATION TO CONTINUE RULE 26(f) SCHEDULING CONFERENCE vs. 15 16 17 CORTECH WEST STAFFING, LLC, THYSSENKRUPP MATERIALS NA, INC., THYSSENKRUPP SUPPLY CHAIN SERVICES Ctrm: NA, Inc., TESLA, INC. dba TESLA MOTORS, Judge: INC., and DOES 1 through 50, inclusive, 5 Hon. William B. Shubb 18 Defendants. 19 Complaint Filed: October 24, 2022 Removed to Federal Court Dec. 19, 2022 20 21 22 23 24 25 26 27 28 CASE NO. 2-22-CV-02270-WBS-AC JOINT STIPULATION 1 3 TINA M. JACQUEZ (SBN 218370) Soltman & Wattles LLP 90 E. Thousand Oaks Blvd., Suite 300 Thousand Oaks, CA 91360 Tel: (805) 49707706 / tjacquez@slfesq.com 4 Attorneys for Defendant CORTECH WEST STAFFING, LLC 5 8 BRIAN BERRY (229893) KASSIA STEPHENSON (336175) Morgan, Lewis & Bockius LLP One Market Spear Street Tower San Francisco, CA 94105 Tel: (415) 442-1180 / brian.berry@morganlewis.com / kassia.stephenson@morganlewis.com 9 Attorneys for Defendant TESLA, INC. DBA TESLA MOTORS, INC. 2 6 7 10 11 12 13 14 15 16 17 18 19 B. JAMES FITZPATRICK (SBN: 129056) LAURA L. FRANKLIN (SBN: 282642) FITZPATRICK & SWANSTON 555 S. Main Street Salinas, CA 93901 Telephone: (831) 755-1311 / bjfitzpatrick@fandslegal.com / lfranklin@fandslegal.com LARRY W. LEE (SBN: 228175) HOWARD L. MAGEE (SBN: 185199) Christine S. Lee (SBN: 339947) DIVERSITY LAW GROUP, P.C. 515 South Figueroa Street, Suite 1250 Los Angeles, California 90071 Telephone: (213) 488-6555 / hmagee@diversitylaw.com / christine@diversitylaw.com lwlee@diversitylaw.com / Attorneys for Plaintiff CURTIS WHITE 20 21 22 23 24 25 26 27 28 CASE NO. 2-22-CV-02270-WBS-AC 2. JOINT STIPULATION 1 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: 2 Plaintiff Curtis White (“Plaintiff”) and Defendants CorTech West Staffing, LLC, 3 Thyssenkrupp Materials NA. Inc. and Thyssenkrupp Supply Chain Services NA, Inc. (together, 4 “Thyssenkrupp”), and Tesla, Inc. dba Tesla Motors, Inc. (“Tesla”) (collectively, the “Defendants”) 5 (Plaintiff and Defendant referred to collectively herein as “the Parties”) through their counsels of 6 record, hereby stipulate and agree as follows: 7 WHEREAS, the Parties participated in mediation with Michael Loeb, Esq. on October 5, 8 2023, whereat, a settlement was reached and a Memorandum of Understanding has since been 9 executed; 10 WHEREAS, the Parties’ current deadline to submit a Joint Rule 26(f) Report is July 1, 2024; 11 WHEREAS, as a Scheduling Conference in this matter is set to take place on July 29, 2024; 12 WHEREAS, on May 8, 2024, Honorable Blanca A. Banuelos of the Superior Court of The 13 State of California, For the County of San Joaquin (Case No. STK-CV-UOE-2023-0000029) granted 14 Plaintiff with leave to file a First Amended Complaint for Plaintiff’s Class and Representative 15 Action, which incorporates and subsumes the causes of action and facts in this Action; WHEREAS, Plaintiff’s Motion for Preliminary Approval of Class and Representative Action 16 17 is currently set for August 7, 2024; 18 WHEREAS, in furtherance of promoting judicial economy and administrative efficiency, the 19 Parties jointly request the Scheduling Conference of July 29, 2024, and Joint Rule 26(f) Report 20 deadline of July 1, 2024, be continued by approximately one-hundred and eighty days (180) days, so 21 that the Parties may resolve and completely dispose of this matter. 22 THEREFORE, it is stipulated and agreed to by the between the Parties, by and through their 23 respective counsel of record, that the Rule 26(f) Scheduling Conference currently scheduled to be 24 heard by the Court on July 29, 2024, be continued by approximately one-hundred and eighty days 25 (180) days to January 26, 2025, or as soon thereafter as may be determined by this Court. 26 /// 27 /// 28 /// CASE NO. 2-22-CV-02270-WBS-AC 3. JOINT STIPULATION 1 2 /// DATED: July 1, 2024 3 4 5 CHAD D. GREESON NICHOLAS GIOIELLO LITTLER MENDELSON P.C. 6 7 Attorneys for Defendants THYSSENKRUPP SUPPLY CHAIN SERVICES NA, INC. and THYSSENKRUPP MATERIALS NA, INC. 8 9 10 DATED: July 1, 2024 /s/ Tina M. Jacquez________________________ TINA M. JACQUEZ SOLTMAN & WATTLES LLP 11 12 Attorneys for Defendant CORTECH WEST STAFFING, LLC 13 14 DATED: July 1, 2024 15 /s/ Kassia Stephenson BRIAN BERRY KASSIA STEPHENSON MORGAN, LEWIS & BOCKIUS LLP 16 17 Attorneys for Defendant TESLA, INC. 18 19 20 DATED: July 1, 2024 21 LARRY W. LEE (SBN: 228175) HOWARD L. MAGEE (SBN: 185199) CHRISTINE S. LEE (SBN: 339947) DIVERSITY LAW GROUP, P.C. 22 23 B. JAMES FITZPATRICK (SBN: 129056) LAURA L. FRANKLIN (SBN: 282642) FITZPATRICK & SWANSTON Attorneys for Plaintiff CURTIS WHITE on behalf of himself and all similarly aggrieved employees 24 25 26 27 28 CASE NO. 2-22-CV-02270-WBS-AC 4. JOINT STIPULATION 1 2 3 FILER’S ATTESTATION: I hereby attest that all signatories listed, and on whose behalf this filing is submitted, concur in the filing’s content and have authorized the filing. 4 5 Dated: July 1, 2024 6 /s/ Chad D. Greeson Chad D. Greeson 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CASE NO. 2-22-CV-02270-WBS-AC 5. JOINT STIPULATION 1 2 3 ORDER The Court, having reviewed the Parties’ Joint Stipulation and good cause appearing therefore, hereby orders as follows: 4 IT IS HEREBY ORDERED that the Rule 26(f) Scheduling Conference currently scheduled 5 to be heard by the Court on July 29, 2024, shall be continued to January 27, 2025 at 1:30 p.m. The 6 Parties will participate in an early meeting pursuant to Rule 26(f). The Joint Rule 26(f) Report will 7 be filed by January 13, 2025. 8 . 9 10 IT IS SO ORDERED. 11 Dated: July 2, 2024 12 13 14 15 16 17 18 4882-1761-7357.1 / 078056-1141 19 20 21 22 23 24 25 26 27 28 CASE NO. 2-22-CV-02270-WBS-AC 6. JOINT STIPULATION

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?