Yucesoy v. Uber Technologies, Inc. et al

Filing 113

STIPULATION AND ORDER re 112 STIPULATION WITH PROPOSED ORDER To Change Dates of Upcoming Hearings and Modify Briefing Schedule for Defendants' Motion to Dismiss Plaintiffs' Second Amended Complaint filed by Hakan Yucesoy, S et/Reset Deadlines as to 112 STIPULATION WITH PROPOSED ORDER To Change Dates of Upcoming Hearings and Modify Briefing Schedule for Defendants' Motion to Dismiss Plaintiffs' Second Amended Complaint, 109 MOTION to Dismiss < i>Second Amended Class Action Complaint, 94 MOTION to Compel Defendants' Notice of Motion and Motion to Compel Arbitration as to Plaintiffs Morris and Sanchez. Responses due by 9/18/2015. Replies due by 10/1/2015. Motion Hearing set for 10/21/2015 09:30 AM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen.. Signed by Judge Edward M. Chen on 9/10/15. (bpf, COURT STAFF) (Filed on 9/10/2015)

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GIBSON, DUNN & CRUTCHER LLP
THEODORE J. BOUTROUS, JR., SBN 132099
[e-mail]
DEBRA WONG YANG, SBN 123289
[e-mail]
MARCELLUS A. MCRAE, SBN 140308
[e-mail]
THEANE D. EVANGELIS, SBN 243570
[e-mail]
DHANANJAY S. MANTHRIPRAGADA,
SBN 254433
[e-mail]

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333 South Grand Avenue
Los Angeles, CA 90071-3197
Telephone:
213.229.7000
Facsimile:
213.229.7520
JOSHUA S. LIPSHUTZ, SBN 242557
[e-mail]
KEVIN J. RING-DOWELL, SBN 278289
[e-mail]
555 Mission Street, Suite 3000
San Francisco, CA 94105-0921
Telephone:
415.393.8200
Facsimile:
415.393.8306

SHANNON LISS-RIORDAN, pro hac vice
ADELAIDE PAGANO, pro hac vice
LICHTEN & LISS-RIORDAN, P.C.
729 Boylston Street, Suite 2000
Boston, MA 02116
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
apagano@llr law.com
MATTHEW CARLSON, SBN 273242
CARLSON LEGAL SERVICES
100 Pine Street, Suite 1250
San Francisco, CA 94111
Telephone: [phone]
[e-mail]
Attorneys for Plaintiffs
HAKAN YUCESOY, ABDI MAHAMMED,
MOKHTAR TALHA, BRIAN MORRIS, and
PEDRO SANCHEZ, individually and on behalf
of all others similarly situated

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Attorneys for Defendant
UBER TECHNOLOGIES, INC., RYAN
GRAVES, and TRAVIS KALANICK.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
CASE NO. 3:15-cv-00262-EMC
HAKAN YUCESOY, ABDI MAHAMMED,
MOKHTAR TALHA, BRIAN MORRIS, and
STIPULATION AND [PROPOSED] ORDER
PEDRO SANCHEZ, individually and on
TO CHANGE DATES OF UPCOMING
behalf of all others similarly situated,
HEARINGS AND MODIFY BRIEFING
SCHEDULE FOR DEFENDANTS’ MOTION
Plaintiffs,
TO DISMISS PLAINTIFFS’ SECOND
AMENDED COMPLAINT
v.
UBER TECHNOLOGIES, INC., RYAN
GRAVES, and TRAVIS KALANICK,
Defendants.

Date: October 8, 2015
Time: 1:30 pm
Place: Courtroom 5
Judge: Hon. Edward M. Chen

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STIP. AND [PROPOSED] ORDER TO CHANGE DATES OF UPCOMING HEARINGS AND MODIFY BRIEFING
SCHEDULE FOR DEFENDANTS’ MOTION TO DISMISS PLAINTIFFS’ SECOND AMENDED COMPLAINT

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Pursuant to Civil Local Rule 7-12, the undersigned counsel of record for Plaintiffs Hakan Yucesoy,

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Abdi Mahammed, Mokhtar Talha, Brian Morris, and Pedro Sanchez (“Plaintiffs”) and Defendants

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Uber Technologies, Inc., Ryan Graves, and Travis Kalanick (“Defendants”) (collectively, the

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“Parties”) stipulate and agree as follows:

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WHEREAS, the hearing on Defendants’ Motion to Compel Arbitration as to Plaintiffs Morris
and Sanchez is currently scheduled for October 1, 2015;
WHEREAS, the hearing on Defendants’ Motion to Dismiss Plaintiffs’ Second Amended
Complaint is currently scheduled for October 8, 2015;
WHEREAS, the status conference in the related case of O’Connor v. Uber Technologies, Inc.,
Civ. A. No. 13-3826, is currently scheduled for October 22, 2015;
WHEREAS, the Parties have conferred and agree that it would save time and expense to

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schedule these hearings on the same date, and the Parties are available on October 15, 2015;

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WHEREAS, the deadline for Plaintiffs’ Response to Defendants’ Motion to Dismiss

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Plaintiffs’ Second Amended Complaint is currently September 11, 2015, and the deadline for

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Defendants’ Reply is currently September 18, 2015 (Doc. 109);

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WHEREAS, Plaintiffs requested an extension of their Response deadline, and Defendants

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agreed to extend Plaintiffs’ Response deadline to September 18, 2015 (an additional five business

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days), and Plaintiffs agreed to extend Defendants’ Reply deadline to October 1, 2015 (an additional

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four business days), in light of the Parties’ agreement to move the October 8, 2015 hearing to October

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15, 2015;

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IT IS HEREBY STIPULATED AND AGREED, subject to the Court’s approval, that:
(1)

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October 1, 2015 to October 15, 2015; at 9:30 a.m.
(2)

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The hearing on Defendant’s Motion to Compel Arbitration is continued from

The hearing on Defendant’s Motion to Dismiss Plaintiffs’ Second Amended
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Complaint is continued from October 8, 2015 to October 15, 2015; at 9:30 a.m.
(3)

The deadline for Plaintiffs’ Response to Defendants’ Motion to Dismiss Plaintiffs’
Second Amended Complaint (Doc. 109) is continued to September 18, 2015, and
the deadline for Defendants’ Reply is continued to October 1, 2015; and
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STIP. AND [PROPOSED] ORDER TO CHANGE DATES OF UPCOMING HEARINGS AND MODIFY BRIEFING
SCHEDULE FOR DEFENDANTS’ MOTION TO DISMISS PLAINTIFFS’ SECOND AMENDED COMPLAINT

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(4)

The status conference in the related case of O’Connor v. Uber Technologies, Inc.,
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Civ. A. No. 13-3826, is moved from October 22, 2015 to October 15, 2015.

at 9:30
a.m.

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Dated: September 9, 2015

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SHANNON LISS-RIORDAN
ADELAIDE PAGANO
LICHTEN & LISS-RIORDAN, P.C.

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MATTHEW CARLSON
CARLSON LEGAL SERVICES

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By:

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/s/ Shannon Liss-Riordan

Attorneys for Plaintiffs
HAKAN YUCESOY, ABDI MAHAMMED,
MOKHTAR TALHA, BRIAN MORRIS, and PEDRO
SANCHEZ, individually and on behalf of all others
similarly situated,

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THEODORE J. BOUTROUS, JR.
DEBRA WONG YANG
MARCELLUS A. MCRAE
THEANE D. EVANGELIS
JOSHUA S. LIPSHUTZ
DHANANJAY S. MANTHRIPRAGADA
BRANDON J. STOKER
KEVIN J. RING-DOWELL
GIBSON, DUNN & CRUTCHER LLP

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By: /s/ Dhananjay S. Manthripragada

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Attorneys for Defendants
UBER TECHNOLOGIES, INC., RYAN GRAVES, and
TRAVIS KALANICK

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Dated: September 9, 2015

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STIP. AND [PROPOSED] ORDER TO CHANGE DATES OF UPCOMING HEARINGS AND MODIFY BRIEFING
SCHEDULE FOR DEFENDANTS’ MOTION TO DISMISS PLAINTIFFS’ SECOND AMENDED COMPLAINT

PURSUANT TO THIS STIPULATION, IT IS SO ORDERED. (as modified above)

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In accordance with Local Rule 5-1, the

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hereby attests that the

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. Chen
dward M
Judge E
filer of this document

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Hon. Edward M. Chen

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O ORD D
IT IS S
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UNIT
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Date: ____________________

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9/10/15

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concurrence to the filing of this document has beenN D
obtained from C other signatories hereto.
O F the
IS T RIC T

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STIP. AND [PROPOSED] ORDER TO CHANGE DATES OF UPCOMING HEARINGS AND MODIFY BRIEFING
SCHEDULE FOR DEFENDANTS’ MOTION TO DISMISS PLAINTIFFS’ SECOND AMENDED COMPLAINT

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