O'Sullivan v. AMN Services, Inc.

Filing 57

ORDER re 55 Notice of Settlement; Joint Stipulation to Vacate Case Management Conference and Set Deadline for Fi8ling Motion for Preliminary Approval of Class Action Settlement filed by Christopher O'Sullivan. Case Management Conference of 6/21/13 is vacated. Motion for Preliminary Approval due by 6/21/2013. Motion Hearing set for 7/26/2013 09:30 AM in Courtroom G, 15th Floor, San Francisco before Magistrate Judge Joseph C. Spero. Signed by Judge Joseph C. Spero on 6/18/13. (klhS, COURT STAFF) (Filed on 6/18/2013)

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Alan Harris (SBN 146079)
HARRIS & RUBLE
6424 Santa Monica Boulevard
Los Angeles, California 90038
Telephone: [phone]; Facsimile: 323.962.3004
[e-mail]
David S. Harris (SBN 215224)
NORTH BAY LAW GROUP
116 E. Blithedale Avenue, Suite #2
Mill Valley, California 94941-2024
Telephone: [phone]; Facsimile: 415.388.8770
[e-mail]
James Rush (SBN 240284)
LAW OFFICES OF JAMES D. RUSH
7665 Redwood Blvd., Suite 200
Novato, California 94945-1405
Telephone: [phone]l; Facsimile: 415.897.5316
[e-mail]
Attorneys for Plaintiff Christopher O’Sullivan
Shaun Setareh (SBN 204514)
SETAREH LAW GROUP
9454 Wilshire Blvd. Penthouse
Beverly Hills, California 90212
Telephone: [phone]; Facsimile: 310.888.7771
David Spivak (SBN 179684)
THE SPIVAK LAW FIRM
9454 Wilshire Blvd. Suite 303
Beverly Hills, California 90212
Telephone: [phone]; Facsimile: 310.499.4739
Attorneys for Plaintiff Alice Ogues
Kenneth D. Sulzer (State Bar No. 120253)
Sarah Kroll-Rosenbaum (SBN 272358)
PROSKAUER ROSE LLP nd
2049 Century Park East, 32 Floor
Los Angeles, CA 90067-3206
Telephone: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants AMN Services, LLC,
(improperly named herein as “AMN SERVICES, INC.
dba Medical Express”), AMN Healthcare, Inc., and
AMN Healthcare Services, Inc.,

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NOTICE OF SETTLEMENT; JOINT STIPULATION AND [PROPOSED] ORDER TO VACATE CASE MANAGEMENT CONFERENCE
AND SET DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

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UNTITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CHRISTOPHER O’SULLIVAN,
individually and on behalf of all others
similarly situated,
Plaintiff,
v.
AMN SERVICES, INC. dba Medical
Express, and DOE 1 through and
including DOE 100,

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NOTICE OF SETTLEMENT; JOINT
STIPULATION AND [PROPOSED] ORDER
TO VACATE CASE MANAGEMENT
CONFERENCE AND SET DEADLINE FOR
FILING MOTION FOR PRELIMINARY
APPROVAL OF CLASS ACTION
SETTLEMENT

Defendants.

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Case No. 3:12-cv-02125 JCS

ALICE OGUES, on behalf of herself and
all others similarly situated,
Plaintiff,
v.
AMN SERVICES, LLC, AMN
HEALTHCARE, INC., AMN
HEALTHCARE SERVICES, INC, and
DOES 1 to 50,
Defendants.

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NOTICE OF SETTLEMENT; JOINT STIPULATION AND [PROPOSED] ORDER TO VACATE CASE MANAGEMENT CONFERENCE
AND SET DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

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STIPULATION

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Plaintiffs Christopher O’Sullivan and Alice Ogues (“Plaintiffs”) and Defendants

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AMN Services, LLC, AMN Healthcare, Inc., and AMN Healthcare Services, Inc

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(“Defendants”) (collectively “the Parties”), stipulate and agree as follows:

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WHEREAS, on April 18, 2013, the Parties had a full day mediation session with

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Mark Rudy in Los Angeles, California, at which time the Parties were unable to settle the

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case but agreed to continue settlement discussions;

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WHEREAS, the Parties since the last mediation session continued settlement

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discussions through Mark Rudy and on June 14, 2013, the Parties reached a settlement

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memorialized in a Memorandum of Understanding resolving this matter on a class-wide

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basis;

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WHEREAS, this case currently is scheduled for a Case Management Conference
on June 21, 2013 at 1:30 P.M. (“the Case Management Conference”);

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WHEREAS, the Parties believe it would conserve judicial resources and promote

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efficiency to vacate the Case Management Conference in light of the resolution of this

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case;

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WHEREAS, the Parties have agreed that Plaintiff’s Motion for Preliminary

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Approval of Class Action Settlement (“Motion For Preliminary Approval”) shall be filed

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on or before June 21, 2013, and shall be set for hearing on July 26, 2013, or as soon

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thereafter as is convenient for the Court;

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WHEREAS, there is no trial date set for this case;

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NOTICE OF SETTLEMENT; JOINT STIPULATION AND [PROPOSED] ORDER TO VACATE CASE MANAGEMENT CONFERENCE
AND SET DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

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IT IS HEREBY STIPULATED by the Parties herein, through their counsel of
record, as follows:

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The Case Management Conference shall be vacated and the Motion for

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Preliminary Approval shall be filed on or before June 21, 2013, and shall be set for

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hearing on July 26, 2013, or as soon thereafter as is convenient for the Court.

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IT IS SO STIPULATED.

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NORTH BAY LAW GROUP

DATED: June 14, 2012

__________/s/___________________
David S. Harris
Attorneys for Plaintiff
CHRISTOPHER O’SULLIVAN

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DATED: June 14, 2012

SETAREH LAW GROUP

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__________/s/___________________
Shaun Setareh
Attorneys for Plaintiff
ALICE OGUES

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DATED: June 14, 2012

PROSKAUER ROSE LLP

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__________/s/___________________
Kenneth D. Sulzer
Attorneys for Defendants
AMN SERVICES, LLC, AMN
HEALTHCARE, INC., and
AMN HEALTHCARE SERVICES,
INC.

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NOTICE OF SETTLEMENT; JOINT STIPULATION AND [PROPOSED] ORDER TO VACATE CASE MANAGEMENT CONFERENCE
AND SET DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

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[PROPOSED] ORDER
The parties having so stipulated, and GOOD CAUSE APPEARING
THEREFORE, IT IS HEREBY ORDERED that:
The Case Management Conference set for June 21, 2013, at 1:30 p.m. is
VACATED.

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Plaintiff shall file the Motion for Preliminary Approval on or before June 21, 2013.

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The hearing on the Motion for Preliminary Approval shall take place on July 26,
2013, at 9:30 a.m. in Courtroom 5.
S

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Judge Jo

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Spero

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R NIA

seph C.

NO

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__________________________________
Honorable Joseph C. Spero
United States District Court Magistrate Judge
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DATED: June __, 2013

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NOTICE OF SETTLEMENT; JOINT STIPULATION AND [PROPOSED] ORDER TO VACATE CASE MANAGEMENT CONFERENCE
AND SET DEADLINE FOR FILING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT