Cordas v. Uber Technologies, Inc.

Filing 20

STIPULATION AND ORDER for 60-Day Stay to Permit Joint Factual Investigation. Signed by Judge Richard Seeborg on 8/29/16. (cl, COURT STAFF) (Filed on 8/29/2016)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Shon Morgan (Bar No. 187736)
2
[e-mail]
865 South Figueroa Street, 10th Floor
3 Los Angeles, California 90017-2543
Telephone:
[phone]
[phone]
4 Facsimile:
Arthur M. Roberts (Bar No. 275272)
[e-mail]
6 50 California Street, 22nd Floor
San Francisco, California 94111
[phone]
7 Telephone:
Facsimile:
[phone]
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Attorneys for Defendant Uber Technologies, Inc.
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10 Kristopher P. Badame (Bar No. 210349)
Joseph H. Hunter (Bar No. 137796)
11 Michele E. Pillette (Bar No. 262031)
BADAME & ASSOCIATES, APC
12 25432 Trabuco Road, Suite 207
Lake Forest, CA 92630
13 [phone]
[phone] – FAX
14 [e-mail]
[e-mail]
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Attorneys for Plaintiff Michael Cordas
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA,
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SAN FRANCISCO DIVISION
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MICHAEL CORDAS, individually, and on
Case No. 3:16-cv-04065-RS
20 behalf of all those similarly situated,
STIPULATION AND [PROPOSED]
Plaintiffs,
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ORDER FOR 60-DAY STAY TO PERMIT
JOINT FACTUAL INVESTIGATION
vs.
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Complaint filed:
July 20, 2016
23 UBER TECHNOLOGIES, INC., and DOES 1
through 50, inclusive,
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Defendants.
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Case No. 3:16-cv-04065-RS
Stipulation and [Proposed] Order for 60-Day Stay to Permit Joint Factual Investigation

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Plaintiff Michael Cordas and defendant Uber Technologies, Inc. hereby stipulate as

2 follows:
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WHEREAS, Plaintiff filed the Complaint on July 20, 2016 and served it on Defendant on

4 July 21, 2016;
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WHEREAS, the parties filed a stipulation pursuant to L.R. 6-1(a) extending the time to

6 answer or otherwise respond to the Complaint until September 12, 2016;
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WHEREAS, counsel for the parties have had discussions regarding the nature of the

8 dispute, allegations in the Complaint, defenses to those allegations, and scheduling;
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WHEREAS, counsel for the parties share an interest in advancing this matter as efficiently

10 and expeditiously as possible and would like to continue these discussions;
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WHEREAS, the parties intend in the coming weeks to further informally exchange factual

12 analyses and continue discussions to evaluate the claims and defenses;
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WHEREAS, extending the time Uber has to answer or otherwise respond to the complaint

14 will not alter the date of any event or any deadline already fixed by Court order.
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THEREFORE, IT IS HEREBY STIPULATED AND AGREED that this matter shall be

16 stayed until October 26, 2016 to permit the parties to pursue these discussions, and Uber shall
17 answer or otherwise respond to the Complaint by November 18, 2016.
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19 DATED: August 26, 2016
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By /s/ Shon Morgan1
Shon Morgan
Attorneys for Uber Technologies, Inc.

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1

Pursuant to L.R. 5-1(i), I, Shon Morgan, attest that I have obtained concurrence in the filing
28 of this document from each of the signatories.
Case No. 3:16-cv-04065-RS
-2Stipulation and [Proposed] Order for 60-Day Stay to Permit Joint Factual Investigation

1 DATED: August 26, 2016

BADAME & ASSOCIATES, APC

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By /s/ Kristopher P. Badame
Kristopher P. Badame
Attorneys for Plaintiff Michael Cordas

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8 PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Date: 8/29/16
Judge Richard Seeborg

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Case No. 3:16-cv-04065-RS
-3Stipulation and [Proposed] Order for 60-Day Stay to Permit Joint Factual Investigation