Dana Rhinerson, et al -v- Van's International Foods, Inc.

Filing 66

Order by Hon. Vince Chhabria granting 65 Stipulation Granting Leave to File Amended Complaint.(knm, COURT STAFF) (Filed on 10/20/2014)

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ATTORNEY’S AT LAW
THE TOWER BUILDING
1970 BROADWAY, NINTH FLOOR
OAKLAND, CA 94612
TEL: [phone]

SCOTT COLE & ASSOCIATES, APC

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Scott Edward Cole, Esq. (S.B. #160744)
Molly A. DeSario, Esq. (S.B. #230763)
Stephen Noel Ilg, Esq. (S.B. #275599)
SCOTT COLE & ASSOCIATES, APC
1970 Broadway, Ninth Floor
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Web: www.scalaw.com
Attorneys for Representative Plaintiffs
and the Plaintiff Classes
Dale J. Giali (Cal. Bar No. 150382)
[e-mail]
Michael L. Resch (Cal. Bar No. 202909)
[e-mail]
MAYER BROWN LLP
350 South Grand Avenue, 25th Floor
Los Angeles, CA 90071-1503
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
VAN’S INTERNATIONAL FOODS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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DANA RHINERSON and AIDIN
MORADI, individually, and on behalf
of all others similarly situated,
Plaintiffs,

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vs.
VAN’S INTERNATIONAL FOODS,
INC., d/b/a Van’s Natural Foods,
Defendant.

) Case No. 3:13-CV-05923 VC
)
) CLASS ACTION
)
) STIPULATION AND [PROPOSED] ORDER
) GRANTING LEAVE TO FILE AMENDED
)
) COMPLAINT
)
) Honorable Vince Chhabria
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)
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Stipulation and [PROPOSED] Order Granting Leave To File Amended Complaint

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Pursuant to Civil Local Rule 7-12, Plaintiffs Dana Rhinerson and Aidin Moradi (“Plaintiffs”)

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and Defendant Van’s International Foods (“Defendant”) (collectively, “the Parties”), by and through

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their counsel hereby stipulate and agree as follows:
WHEREAS, on December 20, 2013, Plaintiffs filed their Complaint for Damages with this

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Court indentifying Van’s International Foods, Inc. as a Defendant in this action.

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WHEREAS, Defendant informed Plaintiffs that its legal name does not contain “Inc.”

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WHEREAS, counsel for both Parties met and conferred with respect to Defendant’s legal

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name.
WHEREAS, both Parties agreed that Plaintiffs should be permitted to amend the pleadings to

THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and between the Parties,

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ATTORNEY’S AT LAW
THE TOWER BUILDING
1970 BROADWAY, NINTH FLOOR
OAKLAND, CA 94612
TEL: [phone]

correct Defendant’s legal name.

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SCOTT COLE & ASSOCIATES, APC

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through their respective counsel of record, as follows:

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1.

The Parties stipulate and agree that Plaintiffs can file their First Amended Complaint

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to change Defendant’s name from “Van’s International Foods, Inc.” to “Van’s International Foods,”

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and subject to the approval of the Court, the proposed First Amended Complaint shall be in the form

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attached hereto as Exhibit “A.”

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2.

Plaintiffs shall file their First Amended Complaint within 30 days of the date this

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Order is entered.

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IT IS SO STIPULATED.

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Dated: October 17, 2014
SCOTT COLE & ASSOCIATES, APC

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By:

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/s/ Stephen Noel Ilg
Stephen Noel Ilg
Attorneys for Representative Plaintiffs
and the Plaintiff Classes

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-2Stipulation and [PROPOSED] Order Granting Leave To File Amended Complaint

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Dated: October 17, 2014

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MAYER BROWN LLP
By:

/s/ Dale Giali
Dale J. Giali
Attorneys for Defendant
Van’s International Foods

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I, Stephen Noel Ilg, hereby attest, pursuant to N.D. Cal. Local Rule 5-1(i)(3) that concurrence
to the filing of this document has been obtained from each signatory.

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By:

/s/ Stephen Noel Ilg
Stephen Noel Ilg
Attorneys for Representative Plaintiffs
and the Plaintiff Classes

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ATTORNEY’S AT LAW
THE TOWER BUILDING
1970 BROADWAY, NINTH FLOOR
OAKLAND, CA 94612
TEL: [phone]

SCOTT COLE & ASSOCIATES, APC

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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October 20, 2014
DATED: _________________

_______________________________
HONORABLE VINCE CHHABRIA
United States District Court Judge

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-3Stipulation and [PROPOSED] Order Granting Leave To File Amended Complaint