Josephson v. Lamon Construction Co., Inc.

Filing 58

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 1/27/2025 AMENDING the PAGA Settlement Agreement. (Deputy Clerk RRB)

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1 6 BRANDON BROUILLETTE, ESQ. (SBN 273156) CHAD SAUNDERS, ESQ. (SBN 257810) ZACHARY M. CROSNER, ESQ. (SBN 272295) CROSNER LEGAL, PC 9440 Santa Monica Blvd. Suite 301 Beverly Hills, CA 90210 Tel. (866) 276-7637 Fax (310) 510-6429 Email: bbrouillette@crosnerlegal.com Email: chad@crosnerlegal.com Email: zach@crosnerlegal.com 7 Attorneys for Plaintiff David Josephson 8 AARON B. SILVA (SBN 245483) MURPHY AUSTIN ADAMS SCHOENFELD LLP 555 Capitol Mall, Suite 850 Sacramento, CA 95814 Telephone: (916) 446-2300 Facsimile: (916) 503-4000 Email: asilva@murphyaustin.com 2 3 4 5 9 10 11 12 13 Attorneys for Defendant Lamon Construction Company, Inc. 14 UNITED STATES DISTRICT COURT 15 EASTERN DISTRICT OF CALIFORNIA 16 17 DAVID JOSEPHSON, as an individual on behalf of himself and on behalf of all others similarly situated, 18 Plaintiff, 19 Case No. 2:23-cv-00043-AC STIPULATION AND [PROPOSED] ORDER TO AMEND THE PAGA SETTLEMENT AGREEMENT v. 20 21 22 23 LAMON CONSTRUCTION COMPANY, INC., a California Corporation, and DOES 1100, inclusive, Defendants. 24 25 26 27 28 STIPULATION AND ORDER TO AMEND THE PAGA SETTLEMENT AGREEMENT 1 STIPULATION 2 Plaintiff David Josephson (“Plaintiff”) and Defendant Lamon Construction Company Inc. 3 (“Defendant”) (together, the “Parties”), by and through their undersigned counsel of record, hereby 4 stipulate and agree as follows: 5 1. Pursuant to Paragraph 8 of the Parties’ PAGA Settlement Agreement, Defendant has 6 elected to shorten the PAGA Period from November 14, 2021, through August 5, 2024, 7 to November 14, 2021, through July 6, 2024. 8 2. The definition of PAGA Period in Paragraph 1.22 of the PAGA Settlement Agreement 9 is amended to read: “’PAGA Period’ means the period from November 14, 2021, to July 10 6, 2024.” 11 12 3. No other provision of the PAGA Settlement Agreement will be affected by Defendant’s election to shorten the PAGA Period. 13 14 STIPULATED AND AGREED BY: 15 16 17 MURPHY AUSTIN ADAMS SCHOENFELD LLP Dated: January 23, 2025 18 By: 19 20 21 22 23 Dated: January 23, 2025 /s/ Aaron B. Silva (as authorized 01/23/25) AARON B. SILVA Attorneys for Defendant Lamon Construction Company, Inc. CROSNER LEGAL, P.C. By: /s/ Chad Saunders CHAD SAUNDERS Attorneys for Plaintiff David Josephson 24 25 26 27 28 STIPULATION AND ORDER TO AMEND THE PAGA SETTLEMENT AGREEMENT 1 2 3 [PROPOSED] ORDER 4 Pursuant to the Parties’ stipulation, the Court hereby Orders as follows: 5 1. Pursuant to Paragraph 8 of the Parties’ PAGA Settlement Agreement, Defendant has 6 elected to shorten the PAGA Period from November 14, 2021, through August 5, 2024, 7 to November 14, 2021, through July 6, 2024. 8 2. The definition of PAGA Period in Paragraph 1.22 of the PAGA Settlement Agreement 9 is amended to read: “’PAGA Period’ means the period from November 14, 2021, to July 10 6, 2024.” 11 12 3. No other provision of the PAGA Settlement Agreement will be affected by Defendant’s election to shorten the PAGA Period. 13 14 15 Dated: January 27, 2025 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND ORDER TO AMEND THE PAGA SETTLEMENT AGREEMENT

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