Medina v. SEIU United Healthcare Workers West

Filing 19

STIPULATION AND ORDER, Motions terminated: 14 MOTION for Temporary Restraining Order filed by Elizabeth Medina, 17 STIPULATION WITH PROPOSED ORDER Regarding TRO & Hearing & Motion to Dismiss filed by SEIU United Healthcare Worker s West, Elizabeth Medina., Set/Reset Deadlines as to 17 STIPULATION WITH PROPOSED ORDER Regarding TRO & Hearing & Motion to Dismiss, 14 MOTION for Temporary Restraining Order , 4 MOTION to Dismiss . Responses due by 4/5/2013. Replies due by 4/22/2013.. Signed by Judge ARMSTRONG on 3/13/13. (lrc, COURT STAFF) (Filed on 3/13/2013)

JACQUELINE MITTELSTADT, ESQ.

BRUCE A. HARLAND, SBN 230477
MANUEL A. BOÍGUES, SBN 248990

SBN 172188
MITTELSTADT LAW
1034 Emerald Bay Road, No. 413
South Lake Tahoe, California 96150
Telephone [phone]
Facsimile [phone]
[e-mail]

Weinberg, Roger & Rosenfeld
A Professional Corporation
1001 Marina Village Parkway, Suite 200
Alameda, CA 94501-1091
Tel [phone]
Fax [phone]

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[e-mail]

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[e-mail]
Attorneys for Defendant
SEIU – UNITED HEALTHCARE
WORKERS - WEST

Attorneys for Plaintiff / Petitioner,
ELIZABETH MEDINA

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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ELIZABETH MEDINA, an individual,

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Plaintiff,

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vs.
SEIU – UNITED HEALTHCARE
WORKERS - WEST, and DOES 1 through 25,
inclusive,

Case No.: C13-858-SBA
XXXXXXXXXX
STIPULATION AND [PROPOSED]
ORDER REGARDING TEMPORARY
RESTRAINING ORDER & HEARING
AND FOR BRIEFING ON DEFENDANT’S
MOTION TO DISMISS

Defendant.

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Plaintiff, by and through her attorney Jacqueline Mittelstadt, and Defendant, by and through its

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attorneys, Weinberg, Roger & Rosenfeld, hereby submit this Stipulation wherein the Parties

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agree to the following:

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Mittelstadt Law
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1034 Emerald Bay
Road, No 413
SLT, CA 96150

______________________________________________________________________________________________________
STIPULATION AND ORDER
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Case No.: C13-858-NC

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

Defendant agrees to hold SEIU-UHW’s internal grievance appeal hearing, currently
scheduled for March 13, 2013 at 7:00 p.m., in abeyance until further order of this Court,

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agreement of the Parties, or the termination of this matter.
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

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Plaintiff withdraws her Request for Restraining Order filed on March 7, 2013 and
currently pending before the Court.



The Parties further agree that with regard to the pending SEIU-UHW’s Motion to

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Dismiss, Plaintiff’s brief in opposition to the Union’s motion to dismiss is due on April

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5, 2013; Defendant’s reply, if any reply is due on April 22, 2013.

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IT IS SO STIPULATED:
IT IS SO STIPULATED:

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Dated: March 11, 2013
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MITTELSTADT LAW
By: /s/ Jacqueline Mittelstadt
Jacqueline Mittelstadt
Attorney for Plaintiff ELIZABETH MEDINA

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WEINBERG, ROGER & ROSENFELD

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Dated: March 11, 2013

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By: /s/ Manuel A. Boigues
MANUEL A. BOÍGUES
Attorneys for Defendant SEIU – UNITED
HEALTHCARE WORKERS - WEST

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IT IS HEREBY ORDERED:

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Dated: ____________________
3/13/13

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__________________________________
HON. SAUNDRA BROWN ARMSTRONG
SENIOR UNITED STATES DISTRICT JUDGE

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Mittelstadt Law
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1034 Emerald Bay
Road, No 413
SLT, CA 96150

______________________________________________________________________________________________________
STIPULATION AND ORDER
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Case No.: C13-858-NC