Craig McDonald v. The Ritz Carlton San Francisco et al

Filing 39

STIPULATION AND ORDER 37 Granting Leave to Plaintiff to File Second Amended Complaint. Signed by Judge Richard Seeborg on 3/3/16. (cl, COURT STAFF) (Filed on 3/3/2016)

1 Krsto Mijanovic (Bar No. 205060)
[e-mail]
2 Leah B. Mason (Bar No. 240425)
[e-mail]
3 HAIGHT BROWN & BONESTEEL LLP
555 South Flower Street, Forty-Fifth Floor
4 Los Angeles, California 90071
Telephone: [phone]
5 Facsimile: 213.542.8100
6 Attorneys for DOMETIC CORPORATION
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

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CRAIG McDONALD,

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Plaintiff,
v.

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THE RITZ-CARLTON HOTEL CO.,
14 LLC; MARRIOTT
INTERNATIONAL, INC.; DOMETIC
15 CORPORATION; and DOMETIC
SALES CORPORATION,
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Defendants.
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Case No. 15-cv-02754-RS
STIPULATION AND [PROPOSED]
ORDER GRANTING LEAVE TO
PLAINTIFF TO FILE SECOND
AMENDED COMPLAINT

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WHEREAS, Plaintiff seeks a court order for leave to amend his complaint to:

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1. Add a new party, namely, Electrolux Home Products, Inc., as a

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defendant;

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2. Remove Marriott International, Inc. as a defendant;

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3. Remove Dometic Sales Corporation as a defendant; and

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4. To make other miscellaneous changes.

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WHEREAS, Plaintiff and Defendants stipulate to Plaintiff filing of the

26 Second Amended Complaint, which is attached hereto as Exhibit A; and,
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WHEREAS the parties agree that Defendants preserve all rights to file a

28 responsive pleading to Plaintiff’s Second Amended Complaint, including crossHD99-0000038
11875238.1
1294741.1

1

STIPULATION AND [PROPOSED] ORDER
GRANTING LEAVE TO PLAINTIFF TO FILE
SECOND AMENDED COMPLAINT

1 claims for indemnification, contribution, and declaratory relief against Electrolux
2 Home Products, Inc.
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NOW THEREFORE Plaintiff and Defendants, by and through their

4 respective attorneys of record, jointly request that the Court issue an order granting
5 Plaintiff leave to file a Second Amended Complaint.
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IT IS SO STIPULATED:

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8 Dated: March 3, 2016
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HAIGHT BROWN & BONESTEEL LLP
By:

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12 Dated: March 2, 2016
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LIEFF CABRASER HEIMANN &
BERNSTEIN, LLP
By:

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15
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17 Dated: March 3, 2016
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/s/ Todd A. Walburg
Todd A. Walburg
Attorneys for Plaintiff CRAIG
MCDONALD

LOMBARDI, LOPER & CONANT, LLP
By:

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/s/ KrstoMijanovic
Krsto Mijanovic
Attorneys for DOMETIC CORPORATION

/s/ Maria M. Lampasona
Maria M. Lampasona
Attorneys for Defendant THE RITZCARLTON HOTEL CO., LLC

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23 IT IS SO ORDERED:
24 DATED: _______________, 2016
3/3
25
26
UNITED STATES DISTRICT JUDGE

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28
HD99-0000038
11875238.1
1294741.1

2

STIPULATION AND [PROPOSED] ORDER FOR
AN ORDER GRANTING LEAVE TO PLAINTIFF
TO FILE FIRST AMENDED COMPLAINT