Sadeghi et al v. Aramark Refreshment Services, LLC

Filing 15

STIPULATION AND ORDER re 14 STIPULATION WITH PROPOSED ORDER to Continue Initial Case Management Conference of April 14, 2016 filed by Aramark Refreshment Services, LLC. Case Management Statement due by 4/14/2016. Initial Case Management Conference set for 4/21/2016 09:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 3/7/16. (bpfS, COURT STAFF) (Filed on 3/7/2016)

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MORGAN, LEWIS & BOCKIUS LLP
Melinda S. Riechert, Bar No. 65504
Lyndsey M. Marcelino, Bar No. 299879
One Market, Spear Street Tower
San Francisco, CA 94105-1596
Tel.: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
ARAMARK REFRESHMENT SERVICES, LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MASIH SADEGHI, ABDUL BENJAMIN,
MONICA JONES, AND BRANDI
CRAWFORD,

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STIPULATION AND [PROPOSED]
ORDER TO CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE OF
APRIL 14, 2016

Plaintiffs,

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Case No. 3:16-cv-00176-EMC

vs.
ARAMARK REFRESHMENT SERVICES,
LLC; DOES 1 through 100, inclusive,

Complaint filed: June 22, 2015

Defendants.

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Plaintiff’s Masih Sadehi, Abdul Benjamin, Monica Jones, and Brandi Crawford

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(“Plaintiffs”) and Defendant Aramark Refreshment Services, LLC (“Defendant”), by and through

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their respective undersigned counsel, hereby stipulate as follows:

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WHEREAS, Plaintiffs filed but did not serve on Defendant their complaint in Alameda
County Superior Court on June 22, 2015, case number HG15775025;
WHEREAS, Plaintiff filed a First Amended Complaint in Alameda County Superior
Court on November 23, 2015;
WHEREAS, Defendant answered the First Amended Complaint in Alameda County
Superior Court on January 7, 2016;
WHEREAS, Defendant timely removed the case to this Court on January 11, 2016;

MORGAN, LEWIS &
BOCKIUS LLP

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ATTORNEYS AT LAW
SAN FRANCISCO

DB2/ 29844686.2

STIPULATION AND [PROPOSED] ORDER TO
CONTINUE INITIAL CMC OF APRIL 14, 2016

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WHEREAS, on January 13, 2016, this case was reassigned to Judge Chen;
WHEREAS, on January 29, 2014, Judge Chen issued an order scheduling the initial Case
Management Conference for April 14, 2016 at 9:30 a.m.;
WHEREAS, lead counsel for Defendant, Melinda Riechert is unavailable on April 14,
2016 because she will be traveling outside of the United States;
WHEREAS, pursuant to Civil Local Rule 16-3, Lead Counsel for Defendant is required to
be present at the Case Management Conference to confer and plan as mandated by Federal Rule
of Civil Procedure 26(f);
WHEREAS, the Parties have never requested a continuance in this matter;
WHEREAS, continuing the April 14, 2016 Case Management Conference to April 21,
2016 or to a date thereafter mutually convenient for the Court will not affect the schedule for the
remaining case or prejudice the Parties.
NOW THEREFORE IT IS HEREBY STIPULATED THAT the Case Management
Conference hearing is continued until at least April 21, 2016 or to a date thereafter mutually
convenient for the Court.

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Respectfully submitted,

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BENJAMIN LAW GROUP, P.C.

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DATED: March 4, 2016
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By

/s/ Na’il Benjamin__________________
Na’il Benjamin
Attorneys for Plaintiffs
MASIH SADEGHI, et al.

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Respectfully submitted,

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MORGAN, LEWIS & BOCKIUS LLP

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DATED: March 4, 2016
By

/s/ Melinda S. Riechert_____________
Melinda S. Riechert
Attorneys for Defendant
ARAMARK REFRESHMENT SERVICES,
LLC

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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DB2/ 29844686.2

STIPULATION AND [PROPOSED] ORDER TO
CONTINUE INITIAL CMC OF APRIL 14, 2016

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[PROPOSED] ORDER

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Good cause appearing, the Case Management Conference currently scheduled for
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April 14, 2016 and 9:30 a.m., shall be continued to the new date of to April 21, 2015 or to

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a date thereafter mutually convenient for the Court.
IT IS SO ORDERED.

________________________________
HON. EDWARD M. CHEN ERED
D
UNITED STATESSO OR
D
IT IS DISTRICT JUDGE

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. Chen

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UNIT
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3/7
Dated: ____________________, 2016

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S DISTRICT
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Joint CMC statement due April 14,
2016.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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DB2/ 29844686.2

STIPULATION AND [PROPOSED] ORDER TO
CONTINUE INITIAL CMC OF APRIL 14, 2016