Torres et al v. DGA Services, Inc. et al

Filing 17

STIPULATION AND ORDER re 16 STIPULATION WITH PROPOSED ORDER Extending Defendants DGA Services, Inc. dba JIT Transportation and Barrett Business Services, Inc.'s Time to Respond to Plaintiffs' Complaint filed by DGA Services, Inc., Barrett Business Services, Inc. Signed by Judge Jon S. Tigar on March 4, 2014. (wsn, COURT STAFF) (Filed on 3/4/2014)

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TOMAS E. MARGAIN (SBN 193555)
[e-mail]
HUY TRAN (SBN 288196)
[e-mail]
PHUNG H. TRUONG (SBN 287687)
[e-mail]
JUSTICE AT WORK LAW GROUP
84 West Santa Clara Street, Suite 790
San Jose, CA 95113
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
MERCED TORRES and SIMON ZUNIGA

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SAN FRA NCI S CO

ATTO RNEY S AT LAW

H IRSCHFELD K RAEMER LLP

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KRISTIN L. OLIVEIRA (SBN 204384)
[e-mail]
HIRSCHFELD KRAEMER LLP
505 Montgomery Street, 13th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants
DGA SERVICES, INC. dba JIT
TRANSPORTATION and
BARRETT BUSINESS SERVICES, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT

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MERCED TORRES and SIMON
ZUNIGA,

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Plaintiff,
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vs.
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DGA SERVICES, INC. dba JIT
TRANSPORTATION; BARRETT
BUSINESS SERVICES, INC.,

Case No. C 13-05734 JST
JOINT STIPULATION EXTENDING
DEFENDANTS DGA SERVICES, INC. dba
JIT TRANSPORTATION AND BARRETT
BUSINESS SERVICES, INC.’S TIME TO
RESPOND TO PLAINTIFFS’
COMPLAINT
Complaint Filed: December 11, 2013

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Defendants.
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Plaintiffs Merced Torres and Simon Zuniga (“Plaintiffs”) and Defendants DGA Services,
Inc. dba JIT Transportation; Barrett Business Services, Inc. (“Defendants”) (collectively “the

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JOINT STIPULATION EXTENDING DEFENDANTS’ TIME TO RESPOND TO
PLAINTIFFS’ COMPLAINT; CASE NO. C 13-05734 JST

4817-2256-1304

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SAN FRA NCI S CO

ATTO RNEY S AT LAW

H IRSCHFELD K RAEMER LLP

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Parties”), by and through their respective counsel of record, pursuant to Local Rules 6-1 and 6-2,
hereby stipulate and agree that:
WHEREAS, counsel for Defendants was only recently engaged in this matter to represent
both named Defendants, DGA SERVICES, INC. dba JIT TRANSPORTATION and BARRETT
BUSINESS SERVICES, INC., and entered an appearance on behalf of both Defendants on
February 28, 2014;
WHEREAS, Defendant DGA SERVICES, INC. dba JIT TRANSPORTATION’s
response to the Complaint was originally due February 19, 2014;
WHEREAS, Defendant BARRETT BUSINESS SERVICES, INC.’s response to the
Complaint is currently due on March 6, 2014 per the Parties earlier stipulation (Document 11);
WHEREAS, Defendants believe it is efficient and cost-effective to file a joint response to
the Complaint on behalf of both named Defendants; and,
WHEREAS, Plaintiffs recently filed a Motion to Continue the Initial Case Management
Conference, presently set for March 12, 2014, to May 14, 2014, and to continue related ADR and
meet and confer deadlines in accordance with a new date for the initial case management
conference (Document 12), which awaits the Court’s ruling.
IT IS HEREBY STIPULATED by and between the Parties that Defendants DGA
SERVICES, INC. dba JIT TRANSPORTATION and BARRETT BUSINESS SERVICES, INC.
shall have until March 18, 2014 to answer or otherwise respond to Plaintiffs’ Complaint.
IT IS SO STIPULATED.

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Dated: February 28, 2014

JUSTICE AT WORK LAW GROUP

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By: /s/ Phung H. Truong
Tomas Margain
Huy Tran
Phung H. Truong
Attorneys for Plaintiffs
MERCED TORRES and SIMON ZUNIGA

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JOINT STIPULATION EXTENDING DEFENDANTS’ TIME TO RESPOND TO
PLAINTIFFS’ COMPLAINT; CASE NO. C 13-05734 JST

4817-2256-1304

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Dated: February 28, 2014

HIRSCHFELD KRAEMER LLP

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By: /s/ Kristin L. Oliveira
Kristin L. Oliveira
Attorneys for Defendants
DGA SERVICES, INC. dba JIT
TRANSPORTATION and
BARRETT BUSINESS SERVICES, INC.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

R NIA

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HON. JON S. TIGAR
UNITED STATES DISTRICT COURT JUDGE

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Ti ga r

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J u d ge J o

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SAN FRA NCI S CO

By:

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ATTO RNEY S AT LAW

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Dated: March ___, 2014
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ORD
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H IRSCHFELD K RAEMER LLP

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UNIT
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JOINT STIPULATION EXTENDING DEFENDANTS’ TIME TO RESPOND TO
PLAINTIFFS’ COMPLAINT; CASE NO. C 13-05734 JST

4817-2256-1304