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Carolyn H. Cottrell (SBN 166977)
1 David C. Leimbach (SBN 265409)
SCHNEIDER WALLACE
2 COTTRELL KONECKY
WOTKYNS LLP
3 2000 Powell Street, Suite 1400
Emeryville, California 94608
4 Tel: (415) 421-7100
Fax: (415) 421-7105
5 ccottrell@schneiderwallace.com
dleimbach@schneiderwallace.com
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Attorneys for Rachel Moniz
7 and the State of California
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SUPERIOR COURT OF CALIFORNIA
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COUNTY OF SAN MATEO
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11 RACHEL MONIZ, on behalf of the State of Case No. 17CIV01736
California and aggrieved employees,
12 Assigned for All Purposes to
Plaintiff, Hon. Marie S. Weiner, Dept. 2
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vs. JOINT STIPULATION AND [PROPOSED]
14 ORDER CONTINUING MAY 17, 2022
ADECCO USA, INC., and DOES 1-50, HEARING ON PROPOSED INTERVENOR
15 inclusive, PAOLA CORREA’S MOTION TO
INTERVENE
16 Defendants.
Complaint Filed: April 18, 2017
17 Trial Date: None Set
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JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING MAY 17 HEARING ON CORREA’S
MOTION TO INTERVENE
1 Plaintiff Rachel Moniz (“Plaintiff”), Defendant Adecco USA, Inc. (“Defendant”), and
2 Proposed Intervenor Paola Correa (“Correa”), by and through their counsel of record, hereby stipulate
3 as follows:
4 WHEREAS, on April 14, 2022, Proposed Intervenor Correa filed a Motion to Intervene in this
5 matter;
6 WHEREAS, the Motion to Intervene is currently set to be heard on May 17, 2021;
7 WHEREAS, Plaintiff, Defendant, and Correa have met and conferred, and agreed to continue
8 the hearing on the Motion to Intervene to June 7, 2022, which is the same date Plaintiff’s renewed
9 motion for approval of PAGA settlement is currently set for hearing;
10 WHEREAS, in continuing the hearing on Correa’s Motion to Intervene, the Plaintiff,
11 Defendant, and Correa agree on the following briefing schedule: Moniz’s opposition to the Motion
12 to Intervene shall be due on or before May 13, 2022; Correa’s reply to both Defendant’s opposition
13 and Plaintiff’s opposition (in a single brief) shall be due on or before May 24, 2022;
14 WHEREAS, the Plaintiff, Defendant, and Correa agree that the continuance of the hearing on
15 Correa’s Motion to Intervene from May 17, 2022 to June 7, 2022 shall not in any way be construed
16 to serve as a basis to argue the Motion to Intervene is untimely; however, Plaintiff and Defendant
17 preserve any other timeliness arguments unrelated to this continuance;
18 THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and through the
19 Plaintiff’s, Defendant’s, and Correa’s respective counsel as follows:
20 The hearing on Correa’s Motion to Intervene should be continued from May 17, 2022 to June
21 7, 2022 at 2:00PM or as soon thereafter as convenient for the Court.
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Dated: May 10, 2022 SCHNEIDER WALLACE
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COTTRELL KONECKY LLP
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By:
26 Carolyn H. Cottrell
David C. Leimbach
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28 Attorneys for Plaintiff Rachel Moniz and
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JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING MAY 17 HEARING ON CORREA’S
MOTION TO INTERVENE
the State of California
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Dated: May 9, 2022 JACKSON LEWIS, P.C.
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By:
5 Mia Farber
Adam Y. Siegel
6 Scott P. Jang
7 Attorneys for Defendant
ADECCO USA, INC.
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Dated: May 9, 2022 OUTTEN GOLDEN LLP
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12 By:
Jahan C. Sagafi
13 Attorneys for Paola Correa
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[PROPOSED] ORDER
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Having considered the stipulation submitted by Plaintiff Rachel Moniz, Defendant Adecco
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USA, Inc., and Proposed Intervenor Paola Correa, and for good cause shown, the Court ORDERS as
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follows:
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The hearing on Correa’s Motion to Intervene is continued from May 17, 2022 to June
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7, 2022 at 2:00PM.
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IT IS SO ORDERED. __________________________________________
23 THE HONORABLE MARIE S. WEINER
JUDGE PRESIDING
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JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING MAY 17 HEARING ON CORREA’S
MOTION TO INTERVENE
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Carolyn H. Cottrell (SBN 166977) 1 David C. Leimbach (SBN 265409) SCHNEIDER WALLACE 2 COTTRELL KONECKY WOTKYNS LLP 3 2000 Powell Street, Suite 1400 Emeryville, California 94608 4 Tel: (415) 421-7100 Fax: (415) 421-7105 5 ccottrell@schneiderwallace.com dleimbach@schneiderwallace.com 6 Attorneys for Rachel Moniz 7 and the State of California 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SAN MATEO 10 11 RACHEL MONIZ, on behalf of the State of Case No. 17CIV01736 California and aggrieved employees, 12 Assigned for All Purposes to Plaintiff, Hon. Marie S. Weiner, Dept. 2 13 vs. JOINT STIPULATION AND [PROPOSED] 14 ORDER CONTINUING MAY 17, 2022 ADECCO USA, INC., and DOES 1-50, HEARING ON PROPOSED INTERVENOR 15 inclusive, PAOLA CORREA’S MOTION TO INTERVENE 16 Defendants. Complaint Filed: April 18, 2017 17 Trial Date: None Set 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING MAY 17 HEARING ON CORREA’S MOTION TO INTERVENE 1 Plaintiff Rachel Moniz (“Plaintiff”), Defendant Adecco USA, Inc. (“Defendant”), and 2 Proposed Intervenor Paola Correa (“Correa”), by and through their counsel of record, hereby stipulate 3 as follows: 4 WHEREAS, on April 14, 2022, Proposed Intervenor Correa filed a Motion to Intervene in this 5 matter; 6 WHEREAS, the Motion to Intervene is currently set to be heard on May 17, 2021; 7 WHEREAS, Plaintiff, Defendant, and Correa have met and conferred, and agreed to continue 8 the hearing on the Motion to Intervene to June 7, 2022, which is the same date Plaintiff’s renewed 9 motion for approval of PAGA settlement is currently set for hearing; 10 WHEREAS, in continuing the hearing on Correa’s Motion to Intervene, the Plaintiff, 11 Defendant, and Correa agree on the following briefing schedule: Moniz’s opposition to the Motion 12 to Intervene shall be due on or before May 13, 2022; Correa’s reply to both Defendant’s opposition 13 and Plaintiff’s opposition (in a single brief) shall be due on or before May 24, 2022; 14 WHEREAS, the Plaintiff, Defendant, and Correa agree that the continuance of the hearing on 15 Correa’s Motion to Intervene from May 17, 2022 to June 7, 2022 shall not in any way be construed 16 to serve as a basis to argue the Motion to Intervene is untimely; however, Plaintiff and Defendant 17 preserve any other timeliness arguments unrelated to this continuance; 18 THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and through the 19 Plaintiff’s, Defendant’s, and Correa’s respective counsel as follows: 20 The hearing on Correa’s Motion to Intervene should be continued from May 17, 2022 to June 21 7, 2022 at 2:00PM or as soon thereafter as convenient for the Court. 22 Dated: May 10, 2022 SCHNEIDER WALLACE 23 COTTRELL KONECKY LLP 24 25 By: 26 Carolyn H. Cottrell David C. Leimbach 27 28 Attorneys for Plaintiff Rachel Moniz and 1 JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING MAY 17 HEARING ON CORREA’S MOTION TO INTERVENE the State of California 1 2 Dated: May 9, 2022 JACKSON LEWIS, P.C. 3 4 By: 5 Mia Farber Adam Y. Siegel 6 Scott P. Jang 7 Attorneys for Defendant ADECCO USA, INC. 8 9 Dated: May 9, 2022 OUTTEN GOLDEN LLP 10 11 12 By: Jahan C. Sagafi 13 Attorneys for Paola Correa 14 15 [PROPOSED] ORDER 16 Having considered the stipulation submitted by Plaintiff Rachel Moniz, Defendant Adecco 17 USA, Inc., and Proposed Intervenor Paola Correa, and for good cause shown, the Court ORDERS as 18 follows: 19 The hearing on Correa’s Motion to Intervene is continued from May 17, 2022 to June 20 7, 2022 at 2:00PM. 21 22 IT IS SO ORDERED. __________________________________________ 23 THE HONORABLE MARIE S. WEINER JUDGE PRESIDING 24 25 26 27 28 2 JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING MAY 17 HEARING ON CORREA’S MOTION TO INTERVENE