O'Halloran et al v. GCA Services Group, Inc.

Filing 32

ORDER by Judge Haywood S. Gilliam, Jr. Granting 31 Stipulation Granting Plaintiffs Leave of Court to File First. Amended Complaint. (ndrS, COURT STAFF) (Filed on 8/21/2015)

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Angela M. Alioto, (SBN 130328)
Angela Mia Veronese, (SBN 269942)
Matthew J. Wayne, (SBN 283897)
LAW OFFICES OF MAYOR JOSEPH L. ALIOTO
AND ANGELA ALIOTO
700 Montgomery Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs Christopher O’Halloran,
Devon Oliver, and Davion McFarland
Jeremy T. Naftel, State Bar No. 185215
[e-mail]
Nicole A. Legrottaglie, State Bar No. 271416
[e-mail]
CAROTHERS DISANTE & FREUDENBERGER LLP
900 University Avenue
Suite 200
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant GCA Services Group of Texas, LP (erroneously sued as GCA Services
Group, Inc.)

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
Christopher O’Halloran, Devon Oliver,
and Davion McFarland

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Plaintiffs,
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vs.
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GCA Services Group, Inc., and DOES 1 to )
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20,
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Defendants.
______________________________________ )

Case No.: 3:15-cv-00868-HSG
JOINT STIPULATION AND
[PROPOSED] ORDER GRANTING
PLAINTIFFS LEAVE OF COURT TO
FILE FIRST AMENDED COMPLAINT

O’Halloran et al. v. GCA Services Group of Texas, LP
JOINT STIPULATION AND [PROPOSED] ORDER GRANTING PLAINTIFFS
LEAVE OF COURT TO FILE FIRST AMENDED COMPLAINT

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STIPULATION
In accordance with Fed. R. Civ. P. 15 and the Court’s August 18, 2015 Order (Docket
Entry No. 30), Plaintiffs Christopher O’Halloran, Devon Oliver, and Davion McFarland and

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Defendant GCA Services Group of Texas, LP (erroneously sued as GCA Services Group, Inc.)
stipulate and agree as follows:
(1)

On February 26, 2015, Plaintiffs filed their Original Complaint which named

GCA Services Group, Inc., who on Plaintiffs’ information and belief was Plaintiffs’

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presumptive employer, as the only Defendant to this action. See Docket, Document Number 1.
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(2)

On June 23, 2015, Plaintiffs filed a Motion for Leave of Court to File Amended

Complaint. See Docket, Document Number 26.
(3)

Plaintiffs’ Motion requests leave of Court to file an Amended Complaint that

includes GCA Services Group of Texas, LP as a Defendant on the grounds that, on Plaintiffs’

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information and belief, this entity was also Plaintiffs’ presumptive employer. Id.

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(4)

Plaintiffs submitted a proposed amended complaint with their Motion. Id., Ex. 1.

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(5)

Defendant has not opposed, and does not oppose the relief requested through

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Plaintiffs’ Motion.

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WHEREFORE, IT IS HEREBY STIPULATED between the Parties and their respective
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counsel that Plaintiffs should be granted leave of Court to file the First Amended Complaint that
was submitted with Plaintiffs’ Motion.

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O’Halloran et al. v. GCA Services Group of Texas, LP
JOINT STIPULATION AND [PROPOSED] ORDER GRANTING PLAINTIFFS
LEAVE OF COURT TO FILE FIRST AMENDED COMPLAINT

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Date: August 21, 2015

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Respectfully submitted,
LAW OFFICES OF JOSEPH ALIOTO AND ANGELA
ALIOTO

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By:

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/s/ Matthew J. Wayne
Matthew J. Wayne
Attorneys for Plaintiffs

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CAROTHERS DISANTE & FREUDENBERGER LLP
By:
/s/ Jeremy T. Naftel
Jeremy T. Naftel
Attorneys for Defendant
GCA Services Group of Texas, LP

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LOCAL RULE 5-1 ATTESTATION

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In accordance with U.S. District Court for the Northern District of California Civil
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Local Rule 5-1(i)(3), the filing attorney attests that concurrence in the filing of this document

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has been obtained from each of the other Signatories, which shall serve in lieu of their

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signatures on the document.

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The filing attorney will maintain records to support this

concurrence for subsequent production for the Court, if so ordered, or for inspection upon

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request by a party, until one year after the final resolution of the action (including appeal, if
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any).

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LAW OFFICES OF JOSEPH ALIOTO AND ANGELA
ALIOTO

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By:

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Date: August 21, 2015

/s/ Matthew J. Wayne
Matthew J. Wayne
Attorneys for Plaintiffs

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O’Halloran et al. v. GCA Services Group of Texas, LP
JOINT STIPULATION AND [PROPOSED] ORDER GRANTING PLAINTIFFS
LEAVE OF COURT TO FILE FIRST AMENDED COMPLAINT

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ORDER
The Court having reviewed the foregoing Stipulation, and good cause appearing

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therefore:
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IT IS HEREBY ORDERED that Plaintiffs Christopher O’Halloran, Devon Oliver, and

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Davion McFarland are granted leave of Court to file the First Amended Complaint that was

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submitted with their original Motion for Leave of Court to File First Amended Complaint.

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Signed this

21st

day of

August

, 2015.

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Honorable Haywood S. Gilliam, Jr.
UNITED STATES DISTRICT JUDGE

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O’Halloran et al. v. GCA Services Group of Texas, LP
JOINT STIPULATION AND [PROPOSED] ORDER GRANTING PLAINTIFFS
LEAVE OF COURT TO FILE FIRST AMENDED COMPLAINT

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