Goomer v, Akvarr

Filing 48

STIPULATION AND ORDER TO WITHDRAW UNOPPOSED MOTION FOR APPROVAL OF PAGA SETTLEMENT re 47 STIPULATION WITH PROPOSED ORDER filed by Randal Singh Goomer. Signed by Judge Jon S. Tigar on May 9, 2019. (wsnS, COURT STAFF) (Filed on 5/9/2019)

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Stacy North (SBN 219034)
BERMAN NORTH, LLP
2225 E. Bayshore Road, Suite 200
Palo Alto, CA 94303
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
RANDAL SINGH GOOMER
LEWIS BRISBOIS BISGAARD & SMITH LLP
JOSEPH R. LORDAN, SB# 265610
E-Mail: [e-mail]
JONATHAN D. MARTIN, SB# 188744
E-Mail: [e-mail]
333 Bush Street, Suite 1100
San Francisco, California 94104-2872
Telephone: [phone]
Facsimile: 415.434.0882
Attorneys for Defendants
AKVARR, INC. and VIJAI RANGARAJAN
(incorrectly sued herein as “VIJAI
RANGARAJAN RANGARAJAN”)

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RANDAL SINGH GOOMER, an
individual,

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Plaintiff,
v.

Case No. 3:18-CV-02519-JST
STIPULATION TO WITHDRAW
UNOPPOSED MOTION FOR
APPROVAL OF PAGA SETTLEMENT

Date: June 6, 2019
AKVARR, INC., a Delaware corporation;
VIJAI RANGARAJAN RANGARAJAN, an Time: 2:00 p.m.
Courtroom: 9
individual
Judge: The Hon. Jon S. Tigar
Defendants.

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4841-0202-1782.1

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STIPULATION TO WITHDRAW UNOPPOSED MOTION
FOR APPROVAL OF PAGA SETTLEMENT

Case No. 3:18-CV-02519-JST

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Plaintiff RANDAL GOOMER, by and through his attorney of record, Berman North

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LLP, desires to withdraw Plaintiff’s Unopposed Motion for Approval of PAGA Settlement (the

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“Motion”), and Defendants AKVARR, INC. and VIJAI RANGARAJAN, by and through their

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counsel of record, Lewis Brisbois Bisgaard & Smith LLP, consent to the withdrawal

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WHEREAS, on February 19, 2019, Plaintiff filed the Motion with a noticed hearing date
of March 28, 2019.
WHEREAS, on April 19, 2019, the Court continued the hearing. The hearing on the

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Motion is presently set for June 6, 2019 at 2:00 p.m. in San Francisco, Courtroom 9, 19th Floor

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before Judge Jon S. Tigar.

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WHERAS, on April 24, 2019, the Court requested Supplemental Briefing.

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WHERAS, the parties are in the process of negotiating a settlement to include a dismissal

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without prejudice of the PAGA claim, and a release of the remaining, non-PAGA related claims

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for which no Court approval is requested.

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WHEREAS, Plaintiff desires to withdraw his Unopposed Motion for Approval of PAGA
Settlement, and Defendants consent to the withdrawal.
NOW, THEREFORE, by and through their undersigned counsel of record, Plaintiff and
Defendants hereby stipulate to the following:
Plaintiff’s Unopposed Motion for Approval of PAGA Settlement is withdrawn, and the

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hearing on Plaintiff’s Unopposed Motion for Approval of PAGA Settlement, currently scheduled

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for June 6, 2019 at 2:00 p.m., shall be vacated.

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Respectfully submitted,
Dated: May 8, 2019

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BERMAN NORTH LLP
By: __/s/ Stacy North_______________
Stacy North
Attorneys for Plaintiff
RANDAL SINGH GOOMER

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4841-0202-1782.1

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STIPULATION TO WITHDRAW UNOPPOSED MOTION
FOR APPROVAL OF PAGA SETTLEMENT

Case No. 3:18-CV-02519-JST

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Dated: May 8, 2019

LEWIS BRISBOIS BISGAARD & SMITH LLP

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By: __/s/ Jonathan D. Martin___________
Jonathan D. Martin
Attorneys for Defendants
AKVARR, INC. AND VIJAI
RANGARAJAN (INCORRECTLY SUED
HEREIN AS “VIJAI RANGARAJAN
RANGARAJAN”)

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ATTESTATION

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Concurrence in the filing of this document has been obtained from each of the
individual(s) whose electronic signature is attributed above.

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Dated: May 8, 2019

__/s/ Stacy North_______________
Stacy North
Attorneys for Plaintiff
RANDAL SINGH GOOMER

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ORDER

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IT IS SO ORDERED, based on the Stipulation set forth above, and GOOD CAUSE

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APPEARING, that:
Plaintiff’s Unopposed Motion for Approval of PAGA Settlement is withdrawn, and the

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hearing on Plaintiff’s Unopposed Motion for Approval of PAGA Settlement currently scheduled

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for June 6, 2019 at 2:00 p.m. shall be vacated.

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IT IS SO ORDERED.

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May 9,
Dated: _________________ 2019

________________________________
UNITED STATES DISTRICT JUDGE
HON. JON S. TIGAR

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4841-0202-1782.1

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STIPULATION TO WITHDRAW UNOPPOSED MOTION
FOR APPROVAL OF PAGA SETTLEMENT

Case No. 3:18-CV-02519-JST