Richards v. Ernst & Young, LLP

Filing 9

ORDER signed by Judge Garland E. Burrell, Jr on 10/28/2008 GRANTING 8 Stipulation and Orde. CASE TRANSFERRED to District of Northern District of California. Original file, certified copy of transfer order, and docket sheet sent. CASE CLOSED. (Streeter, J)

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CATHERINE A. CONWAY (SBN 98366) GREGORY W. KNOPP (SBN 237615) ANASTASIA M. BOLES (SBN 224980) CHRISTOPHER BLANCHARD (SBN 250729) AKIN GUMP STRAUSS HAUER & FELD LLP 2029 Century Park East, Suite 2400 Los Angeles, California 90067-3012 Telephone: [phone] Facsimile: 310-229-1001 [e-mail] [e-mail] [e-mail] [e-mail] Attorneys for DEFENDANT ERNST & YOUNG LLP

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION MICHELLE RICHARDS, on behalf of herself and all others similarly situated and on behalf of the general public, Plaintiffs, v. ERNST & YOUNG LLP, and DOES 1 - 50, Defendants. Case No. 2:08-CV-01849-GEB-EFB STIPULATION AND [PROPOSED] ORDER TO TRANSFER ACTION TO NORTHERN DISTRICT OF CALIFORNIA

STIPULATION AND [PROPOSED] ORDER TO TRANSFER ACTION TO NORTHERN DISTRICT OF CALIFORNIA

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Plaintiff Michelle Richards ("Plaintiff") and Defendant Ernst & Young LLP ("Defendant"), by and through their respective counsel, hereby agree and stipulate as follows: WHEREAS, Ho v. Ernst & Young LLP, Case No. CV 05-04867 ("The Ho Action") was filed on September 27, 2005 in Santa Clara County Superior Court and was removed to the United States District Court for the Northern District of California on November 29, 2005; WHEREAS, Landon v. Ernst & Young LLP, et al., Case No. CV 08-00889 ("The Landon Action") was filed in Placer County Superior Court on February 21, 2008 and was removed to this Court on April 25, 2008; WHEREAS, the Landon Action was transferred from this Court to the Northern District of California on June 6, 2008 and is now pending in the Northern District of California as Case No. CV 08-02853 and has been deemed related to the Ho Action. WHEREAS, the instant action was filed in Sacramento County Superior Court on June 19, 2008 and was removed to this Court on August 8, 2008; WHEREAS, the instant action involves substantially similar claims and putative classes to those alleged in the Ho Action; and WHEREAS, the parties acknowledge and agree that the proposed transfer will have no impact on either parties' procedural or substantive rights. Plaintiff Richards expressly reserves the right to take discovery regarding not only merits discovery but also class certification discovery, and Ernst & Young expressly reserves any proper objections thereto. Ernst & Young expressly reserves the right to take discovery relating to Plaintiff Richards, and Plaintiff Richards expressly reserves any proper objections thereto. /// /// /// ///
STIPULATION AND [PROPOSED] ORDER TO TRANSFER ACTION TO NORTHERN DISTRICT OF CALIFORNIA

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THE PARTIES HEREBY STIPULATE that this action should be transferred to the Northern District and respectfully request an order to that effect. Dated: _________ HOFFMAN & LAZEAR Ross L. Libenson Attorneys for Plaintiff Michelle Richards Dated: ____________ AKIN GUMP STRAUSS HAUER & FELD LLP Christopher Blanchard Attorneys for Defendant Ernst & YOUNG LLP IT IS SO ORDERED. DATED: October 28, 2008 By By

GARLAND E. BURRELL, JR. United States District Judge

STIPULATION AND [PROPOSED] ORDER TO TRANSFER ACTION TO NORTHERN DISTRICT OF CALIFORNIA