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

Filing 69

Order by Hon. Vince Chhabria granting 68 Stipulation to Deem Defendant Van's International Food's Answer to Plaintiff's Complaint Applicable to Plaintiff's First Amended Complaint.(knm, COURT STAFF) (Filed on 11/26/2014)

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MAYER BROWN LLP
Dale J. Giali (Cal. Bar No. 150382)
[e-mail]
Michael L. Resch (Cal. Bar No. 202909)
[e-mail]
350 South Grand Avenue
25th Floor
Los Angeles, CA 90071-1503
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
VAN’S INTERNATIONAL FOODS
SCOTT COLE AND ASSOCIATES, APC
Scott Edward Cole, Esq. (Cal. Bar No. 160744)
[e-mail]
Molly A. DeSario, Esq. (Cal. Bar No. 230763)
[e-mail]
Stephen Noel Ilg, Esq. (Cal. Bar No. 275599)
[e-mail]
1970 Broadway, Ninth Floor
Oakland, CA 94612
Telephone:
[phone]
Facsimile:
[phone])
Attorneys for Plaintiffs
DANA RHINERSON AND AIDIN MORADI

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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DANA RHINERSON, et al.,
Plaintiffs,

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v.
VAN’S INTERNATIONAL FOODS
Defendant.

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Case No. 3:13-cv-05923
The Honorable Vince Chhabria
STIPULATION AND [PROPOSED]
ORDER TO DEEM DEFENDANT
VAN’S INTERNATIONAL FOOD’S
ANSWER TO PLAINTIFF’S
COMPLAINT APPLICABLE TO
PLAINTIFF’S FIRST AMENDED
COMPLAINT

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Stipulation to Deem Answer Applicable to First Amended Complaint; Case No.: 3:13-CV-05923
711894538

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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 (“Van’s”), by and through their attorneys of record,

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stipulate as follows:

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WHEREAS, on July 16, 2014, Van’s filed an Answer to plaintiffs’ complaint.

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WHEREAS, on October 22, 2014, plaintiffs filed a First Amended Complaint solely to

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correct Van’s legal name to not contain the entity designation “Inc.”
WHEREAS, counsel for both Parties met and conferred with respect to Van’s Answer to the
First Amended Complaint.
WHEREAS, both parties agreed that Van’s previously-filed Answer should be deemed to

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apply to plaintiffs’ First Amended Complaint.

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

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through their respective counsel of record, as follows:

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1.

Defendant Van’s International Foods (Van’s) shall not be required to answer

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plaintiffs’ First Amended Complaint, filed on October 22, 2014, ECF No. 67. In addition, all

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denials, responses, and affirmative defenses contained in Van’s Answer, filed on July 16, 2014, ECF

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No. 54, shall be deemed to be Van’s denials, responses, and affirmative defenses to the First

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Amended Complaint.

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IT IS SO STIPULATED.

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DATED: November 25, 2014

By: /s/ Stephen Noel Ilg
SCOTT EDWARD COLE
MOLLY A. DESARIO
STEPHEN NOEL ILG

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Attorneys for Plaintiffs
DANA RHINERSON AND AIDIN MORADI

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[Proposed] Stipulated Protective Order; Case No.: 3:13-CV-05923
711894538

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DATED: November 25, 2014

By:

s/ Dale J. Giali

DALE J. GIALI
MICHAEL L. RESCH

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Attorneys for Defendant
VAN’S INTERNATIONAL FOODS.

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I, Dale J. Giali, 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:

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DALE J. GIALI

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s/ Dale J. Giali

Attorney for Defendant
VAN’S INTERNATIONAL FOODS.

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: November 26, 2014

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_____________________________________
HON. VINCE CHHABRIA
United States District Judge

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[Proposed] Stipulated Protective Order; Case No.: 3:13-CV-05923
711894538