Yucesoy v. Uber Technologies, Inc. et al

Filing 99

STIPULATION AND ORDER re 98 One-Day Bench Trial filed by Uber Technologies, Inc., Ryan Graves, Travis Kalanick. Bench Trial on the issue whether Plaintiff formed a contract with Uber is set for 11/23/2015 09:30 AM before Edward M. Chen. Signed by Judge Edward M. Chen on 8/14/15. (bpf, COURT STAFF) (Filed on 8/14/2015)

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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]
333 South Grand Avenue
Los Angeles, CA 90071-3197
Telephone: [phone]
Facsimile: 213.229.7520

LICHTEN & LISS-RIORDAN, P.C.
SHANNON LISS-RIORDAN, pro hac vice
[e-mail]
ADELAIDE PAGANO, pro hac vice
[e-mail]
729 Boylston Street, Suite 2000
Boston, MA 02116
Telephone: [phone]
Facsimile: [phone]

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: [phone]
Facsimile: 415.393.8306

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

CARLSON LEGAL SERVICES
MATTHEW CARLSON, SBN 273242
[e-mail]
100 Pine Street, Suite 1250
San Francisco, CA 94111
Telephone: [phone]

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

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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

CASE NO. 13-00262-EMC
STIPULATION AND [PROPOSED] ORDER
RE: ONE-DAY BENCH TRIAL

Plaintiffs,

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v.

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UBER TECHNOLOGIES, INC., RYAN
GRAVES, and TRAVIS KALANICK,

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Defendants.

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Gibson, Dunn &
Crutcher LLP

STIP. AND [PROPOSED] RE: ONE-DAY BENCH TRIAL
CASE NO. 13-00262-EMC

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STIPULATION

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Plaintiffs Hakan Yucesoy, Abdi Mahammed, Mokhtar Talha, Brian Morris, and Pedro

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Sanchez (“Plaintiffs”) and Defendants Uber Technologies, Inc., Ryan Graves, and Travis Kalanick

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(“Defendants”) (collectively, the “Parties”), by and through their respective counsel of record, hereby

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stipulate as follows:

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WHEREAS, on May 22, 2015, Defendants filed a motion to compel arbitration, see Docket
No. 62;

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WHEREAS, on June 23, 2015, Plaintiffs filed their opposition to Defendants’ motion to
compel arbitration, see Docket No. 72;

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WHEREAS, on July 8, 2015, Defendants filed their reply in support of their motion to compel
arbitration, see Docket No. 80;

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WHEREAS the hearing on Defendants’ motion to compel arbitration took place on August 6,
2015;
WHEREAS, the Court ordered the Parties to meet and confer and to submit to the Court by

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August 13, 2015 a proposed scheduling order for a bench trial on the issue of whether Plaintiff

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Yucesoy formed a contract with Uber, see Docket No. 95;

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WHEREAS, the Court has scheduled a further case management conference for November
19, 2015, see id.;
WHEREAS the Parties have conferred and agreed to propose November 19, 2015, for the

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bench trial on the issue of whether Plaintiff Yucesoy formed a contract with Uber, which date would

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be convenient for the Court and the Parties given that a further case management conference in this

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matter has already been scheduled for that day;

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WHEREAS the Parties have conferred and further agreed that the deposition of Mr. Yucesoy

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will occur on November 17, 2015, in San Francisco, California, and that the deposition transcript will

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be in final form by November 19, 2015, for use at trial;

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Gibson, Dunn &
Crutcher LLP

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STIP. AND [PROPOSED] ORDER RE: ONE-DAY BENCH TRIAL
CASE NO. 13-00262-EMC

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NOW THEREFORE, the Parties hereby stipulate to and propose, subject to the approval of
this Court, the following:
The bench trial on the issue of whether Plaintiff Yucesoy formed a contract with Uber will
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at 9:30 a.m.

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occur on November 19, 2015, and the deposition of Mr. Yucesoy will occur on November 17, 2015,

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in San Francisco, California.

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IT IS SO STIPULATED
Dated: August 13, 2015

GIBSON, DUNN & CRUTCHER LLP

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By:

/s/ Theane Evangelis
Theane Evangelis

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

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Dated: August 13, 2015

LICHTEN & LISS-RIORDAN, P.C.

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By:

/s/ Shannon Liss-Riordan
Shannon Liss-Riordan

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Attorney for Plaintiffs HAKAN YUCESOY, ABDI
MAHAMMED, MOKHTAR TALHA, BRIAN
MORRIS, and PEDRO SANCHEZ

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. Bench trial set for
November 23, 2015 at 9:30 a.m.
Further filings, if any,
must be filed by November 9,
2015.

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S
NO

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Crutcher LLP

dward
Judge E

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Gibson, Dunn &

ORDE
T IS SO DIFIED
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AS MO

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M. Che

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R NIA

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The Honorable Edward M. Chen
United States District Judge
RED

FO

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UNIT
ED

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S DISTRICT
TE
__________________________
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8/14

Dated: ___________, 2015

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A

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C
STIP. AND [PROPOSED]R N
ORDER RE: ONE-DAY BENCH TRIAL
CASE NO. D
13-00262-EMC O F
IS T RIC T

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ECF ATTESTATION
I, Dhananjay S. Manthripragada, hereby attest that concurrence in the filing of this document has
been obtained from Theane Evangelis and Shannon Liss-Riordan.

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By:

/s/ Dhananjay S. Manthripragada
Dhananjay S. Manthripragada

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Gibson, Dunn &
Crutcher LLP

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STIP. AND [PROPOSED] ORDER RE: ONE-DAY BENCH TRIAL
CASE NO. 13-00262-EMC