Dietrick v. Securitas Security Services USA, Inc.

Filing 133

STIPULATION AND ORDER re 132 STIPULATION WITH PROPOSED ORDER for Filing and Response to 3rd Amended Complaint filed by Michael Deatrick. Amended Pleadings due by 5/27/2015. Signed by Judge Jon S. Tigar on May 20, 2015. (wsn, COURT STAFF) (Filed on 5/20/2015)

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EDUARDO G. ROY (Bar No. 146316)
DANIEL C. QUINTERO (Bar No. 196492)
JILL DESSALINES (Bar No. 123825)
JOHN R. HURLEY (Bar No. 203641)
PROMETHEUS PARTNERS L.L.P.
220 Montgomery Street Suite 1094
San Francisco, CA 94104
Telephone: [phone]
Attorneys for Plaintiffs
Michael Deatrick, et al.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MICHAEL DEATRICK, individually and on
behalf of all others similarly situated, and as
representative of the State of California,
Plaintiff,

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v.
SECURITAS SECURITY SERVICES USA,
INC.,

Case No.: 3:13-cv-5016 JST
STIPULATION AND [PROPOSED]
ORDER RE FILING OF AND
RESPONDING TO THIRD AMENDED
COMPLAINT
F.R.C.P. 15

Defendant.

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Plaintiffs Michael Deatrick, the Opt-in Plaintiffs, and Defendant Securitas Security Services
USA, Inc. (“Securitas USA”) hereby stipulate and agree as follows:
WHEREAS, Plaintiff filed his original Complaint in this action on October 28, 2013, and a
Second Amended Complaint is the currently operative pleading;
WHEREAS Federal Rule of Civil Procedure 15(a) provides that leave to amend “shall be freely
given when justice so requires;

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WHEREAS Securitas USA does not oppose and agrees to the Amendment;

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WHEREAS Securitas USA reserves all rights to challenge the pleading, and the allegations set

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forth therein, at the appropriate time(s).
IT IS THEREFORE STIPULATED AND AGREED AS FOLLOWS:
1. That Plaintiff shall be given leave to file the Third Amended Complaint submitted
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STIPULATION RE AMENDMENT

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concurrently with this stipulation; within five court days of this order.
ten court days thereafter
2. That Securitas USA shall have 14 days from the date of the order on this stipulation in
which to Answer or otherwise respond to the Third Amended Complaint.
Pursuant to Local Rule 5-1(i)(3), the undersigned filer of this document hereby attests that

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concurrence in the filing has been obtained from each of the other signatories, which shall serve in lieu

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of their signatures on the document.

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IT IS SO STIPULATED.

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DATED: May 18, 2015

Respectfully submitted,
PROMETHEUS PARTNERS L.L.P.

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By:

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/s/ John R. Hurley
John R. Hurley, Esq.
Attorneys for Plaintiffs Michael Deatrick, et al.

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DATED: May 18, 2015

Respectfully submitted,
THARPE & HOWELL, LLP

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By:

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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J u d ge J o

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Jon S. Tigar
United States DistrictSCourt ar
. Tig Judge

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By:

ERED
O ORD D
IT IS S
DIFIE
AS MO

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UNIT
ED

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S DISTRICT
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DATED: May 20, 2015

R NIA

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A

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/s/ Sherry B. Shavit
Sherry B. Shavit, Esq.
Attorneys for Defendant Securitas
Security Services USA, Inc.

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D IS T IC T
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STIPULATION RE AMENDMENT

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