Le v. JPMorgan Chase Bank, N.A.

Filing 8

STIPULATION AND ORDER re 7 STIPULATION WITH PROPOSED ORDER Regarding Amending Complaint filed by Linda Le, JPMorgan Chase Bank, N.A.. Signed by Magistrate Judge Kandis A. Westmore on 6/11/14. (sisS, COURT STAFF) (Filed on 6/12/2014)

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Cary Kletter (SBN 21 0230)
Sally Trung Nguyen (SBN 267275)
KLETTER LAW FIRM LLP
1900 S. Norfolk Street, Suite 350
San Mateo, California 94403
415.434.3400
Attorneys for Plaintiff,
LINDALE

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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LINDALE,

Case No.: C 14-02225 KAW

PLAINTIFF,

STIPULATION AND PROPOSED
ORDER REGARDING
AMENDING COMPLAINT

v.
JPMORGAN CHASE BANK and DOES 1
- 20, inclusive,

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DEFENDANTS.

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STIPULATION

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Plaintiff LINDA LE ("LE") and Defendant JPMORGAN CHASE BANK ("CHASE"),
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through their counsel of record, hereby stipulate as follows:
WHEREAS, LE filed an action with the following claims: ( 1) Pregnancy Discrimination;

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(2) California Family Rights Act ("CFRA") Interference; (3) CFRA Discrimination/Retaliation;

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(4) Fair Employment and Housing Act ("FEHA'') Retaliation; (5) Wrongful Termination in

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Violation of Public Policy; (6) Discrimination on the Basis of Disability; (7) Failm·e to

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Accommodate Disability; (8) Failure to Engage in the Interactive Process; (9) Failure to Provide
Seating; and (1 0) Unfair Business Practices;

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WHEREAS, CHASE filed a Notice of Removal of Civil Action (Federal Question and
Diversity) ("Removal");
WHEREAS, counsel for all parties have agreed to allow LE to file the Attached First
Amended Complaint;

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STIPULATION AND PROPOSED ORDER REGARDING AMENDING COMPLAINT

C 14-02225 KA W

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WHEREAS, no trial date has been set; and
WHEREAS, none of the parties would be prejudiced by allowing LE to file the First
Amended Complaint.
THEREFORE, IT IS HEREBY STIPULATED AND AGREED that LE may file the
attached First Amended Complaint.

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Dated: June 10, 2014

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KLETTER LAW FIRM LLP
CARYKLETTER
SALLY TRUNG NGUYEN

By:~-

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Cary~ter

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Attomey for Plaintiff
LindaLe

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Date: June 10,2014

SANCHEZ & AMADOR, LLP
JAMIE RUDMAN

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By: c:.L:J ..:7-J
--~-=----~
;:::;:::=Jamie Rudman
Attomey for Defendant
JPMorgan Chase Bank

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STIPULATION AND PROPOSED ORDER REGARDING AMENDING COMPLAINT
C 14-.Q2225 KA W

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Case No. C 14-02225 KA W

LINDALE,
Plaintiff,

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vs.

[PROPOSED] ORDER REGARDING
FILING FIRST AMENDED COMPLAINT

JPMORGAN CHASE BANK, and DOES
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Defendants.
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Pursuant to the stipulation of the parties, and for good cause shown, IT IS HEREBY
ORDERED that Plaintiff LindaLe is granted leave to file the First Amended Complaint.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
Date: _ _ _ _ _ _ __
6/11/14
The Honorable Kandis A. Westmore
United States District Court Judge

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STIPULATION AND PROPOSED ORDER REGARDING AMENDING COMPLAINT

C 14-02225 KA W