Feaver et al v. Kaiser Foundation Health Plan, Inc. et al

Filing 42

STIPULATION AND ORDER re #40 STIPULATION WITH PROPOSED ORDER REGARDING DEADLINE TO SUBMIT JOINT CASE MANAGEMENT STATEMENT filed by Kaiser Foundation Health Plan, Inc. Signed by Judge Edward M. Chen on 2/16/16. (bpfS, COURT STAFF) (Filed on 2/16/2016)

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SEYFARTH SHAW LLP
Christian J. Rowley (SBN 187293)
Jason Allen (SBN 284432)
560 Mission Street, 31st Floor
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Richard L. Alfred (SBN 015000) (pro hac vice)
Jessica S. Lieberman (SBN 669677) (pro hac vice)
Two Seaport Lane, Suite 300
Boston, Massachusetts 02210
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ROSE FEAVER, an individual,
MYUNGSHUN SHIM, an individual,
ARTIN ADAMIAN, an individual,
individually, and on behalf of all others
similarly situated,

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Plaintiffs,
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v.
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KAISER FOUNDATION HEALTH PLAN,
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INC., KAISER FOUNDATION HOSPITALS, )
and Does 1 through 50, Inclusive
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Defendants.
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CASE NO.: 3:15-CV-00890-EMC
Assigned To: Hon. Edward M. Chen
CLASS AND COLLECTIVE ACTION
STIPULATION REGARDING
DEADLINE TO SUBMIT JOINT CASE
MANAGEMENT STATEMENT

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TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

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Defendants Kaiser Foundation Health Plan, Inc. and Kaiser Foundation Hospitals, Inc.

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(collectively “Defendant”) and Plaintiffs Rose Feaver, Artin Adamian, and Myungsun Shim

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(collectively “Plaintiffs”) (together, the “Parties”), by and through their respective counsel of
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STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT STATEMENT

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record, hereby stipulate as follows:
1.

On January 5, 2016, the Court set a case management conference for February 18,

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2016, and instructed the Parties to file an updated joint case management statement by February

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11, 2016 (docket no. 38).

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2.

In its Order dated January 27, 2016 granting Plaintiffs’ motion for conditional

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certification (docket no. 39), this Court instructed the Parties to file by February 16, 2016 a

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stipulation governing notice to the conditionally certified collective.

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3.

The case deadlines that the Parties anticipate addressing in the updated joint case

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management statement are dependent in part on the timeline for notice to the conditionally

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certified collective, which the Parties will address in the joint stipulation regarding notice due

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February 16, 2016.

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4.

For this reason, the Parties request an extension of time to file the joint case

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management statement through February 16, 2016, which would allow them to complete and file

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the two documents together.

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Dated: February 10, 2016

SEYFARTH SHAW, LLP

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By: __Jessica S. Lieberman________
Jessica S. Lieberman (pro hac vice)
Attorneys for Defendant

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Dated: February 10, 2016

KEARNEY LITTLEFIELD, LLP
STONEBARGER LAW, APC

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By: __Prescott W. Littlefield________
Prescott W. Littlefield
Attorneys for Plaintiff

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I, Jessica S. Lieberman, hereby attest that pursuant to LR 5-1(i) I have on file concurrence for
any signatures indicated by a “conformed” signature (/s/) within this e-filed document.
/s/ Jessica S. Lieberman
Jessica S. Lieberman
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STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT STATEMENT

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[PROPOSED] ORDER
IT IS SO ORDERED.

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2/16/16
Dated:__________________

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Hon. Edward M. Chen
ERED
United States District Court Judge
O ORD
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ITNorthern District of California

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STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT STATEMENT