Shankle v. TPG Capital, L.P.

Filing 14

ORDER granting 13 STIPULATION WITH PROPOSED ORDER JOINT STIPULATION OF THE PARTIES TO AMEND THE COMPLAINT OF ERICA SHANKLE AND TO FILE THE FIRST AMENDED COMPLAINT filed by Erica Shankle. Signed by Judge Charles R. Breyer on 2/5/2013. (beS, COURT STAFF) (Filed on 2/6/2013)

Case3:12-cv-06181-CRB Document13 Filed02/01/13 Page1 of 3

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CATHERINE A. CONWAY, SBN 98366
[e-mail]
JESSE A. CRIPPS, SBN 222285
[e-mail]
GIBSON, DUNN & CRUTCHER LLP
333 South Grand Avenue
Los Angeles, CA 90071-3197
Telephone: [phone]
Facsimile: 213.229.7520
Attorneys for Defendants
TPG CAPITAL, L.P.

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Joshua G. Konecky (SBN 182897)
[e-mail]
SCHNEIDER WALLACE
COTTRELL KONECKY LLP
180 Montgomery Street, Suite 2000
San Francisco, California 94104
Telephone: [phone]
Facsimile: 415.421.7105

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Jeremy Pasternak (SBN 181618)
[e-mail]
LAW OFFICES OF JEREMY PASTERNAK
445 Bush Street, Sixth Floor
San Francisco, California 94108
Telephone: [phone]
Facsimile: 415.693.0393

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Attorneys for Plaintiff and the Proposed Class

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[Additional counsel appear on signature page]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ERICA SHANKLE on behalf of herself and all
others similarly situated,

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Plaintiffs,
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v.

CASE NO. 12-C-06181 CRB
JOINT STIPULATION OF THE PARTIES
TO AMEND THE COMPLAINT OF ERICA
SHANKLE AND TO FILE THE FIRST
AMENDED COMPLAINT

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TPG CAPITAL, L.P., and DOES 1 through 50,
inclusive,
Defendants.

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Gibson, Dunn &
Crutcher LLP

JOINT STIPULATION OF THE PARTIES TO AMEND THE COMPLAINT OF ERICA SHANKLE AND TO FILE THE FIRST AMENDED
COMPLAINT –CASE NO. 12-C-06181 CRB

Case3:12-cv-06181-CRB Document13 Filed02/01/13 Page2 of 3

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IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES hereto through their
respective counsel as follows:
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Pursuant to Federal Rule of Civil Procedure 15(a), Plaintiff Erica Shankle (“
Plaintiff”
)

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shall be permitted to file the First Amended Complaint attached hereto as Exhibit A without the need

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to file a formal motion. The First Amended Complaint shall be deemed filed as of today’ date,
s

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February 1, 2013, and Defendant does not object to the filing of the First Amended Complaint;

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provided, however that Defendant shall not be required to file an Answer to the First Amended

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Complaint, and all denials, responses and affirmative defenses contained in the Answer filed by the

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Defendant to the original Complaint shall be deemed to apply to the First Amended Complaint.

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2.

The parties agree that Defendant, by filing this stipulation, does not agree that the

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claims set forth in the First Amended Complaint are appropriate, and reserves all rights and defenses,

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including, but not limited to, defenses based on statutes of limitation.

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Dated: February 1, 2013

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LAW OFFICES OF JEREMY PASTERNAK

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/s/

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Jeremy Pasternak

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Attorney for Plaintiff

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Dated: February 1, 2013
SCHNEIDER WALLACE
COTTRELL KONECKY LLP

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/s/

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Joshua Konecky

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Attorney for Plaintiff

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Gibson, Dunn &
Crutcher LLP

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JOINT STIPULATION OF THE PARTIES TO AMEND THE COMPLAINT OF ERICA SHANKLE AND TO FILE THE FIRST AMENDED
COMPLAINT –CASE NO. 12-C-06181 CRB

Case3:12-cv-06181-CRB Document13 Filed02/01/13 Page3 of 3

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Dated: February 1, 2013

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CATHERINE A. CONWAY
RACHEL S. BRASS
JESSE A. CRIPPS
SARAH ZENEWICZ
GIBSON, DUNN & CRUTCHER LLP

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/s/
Jesse A. Cripps

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Attorneys for Defendants
TPG CAPITAL, L.P.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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February 5, 2013
Dated: ____________________
UNIT
ED

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O ORD

IT IS S

ERED

. Breyer
harles R

NO

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A

H

ER

FO

Judge C

LI

RT

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R NIA

The Honorable Charles R. Breyer

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101452747.2

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Gibson, Dunn &
Crutcher LLP

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JOINT STIPULATION OF THE PARTIES TO AMEND THE COMPLAINT OF ERICA SHANKLE AND TO FILE THE FIRST AMENDED
COMPLAINT –CASE NO. 12-C-06181 CRB