Preview
W
JESSICA RIGGIN (SBN 28 1712)
jrz'ggz'n@rukinhyland.com
VALERIE BRENDER (SBN 298224)
vbrender@rukinhyland.com
RUKIN HYLAND & RIGGDI LLP
1939 Harrison Street, Suite 290
Oakland, CA 94612
Telephone: (415) 421-1800
Facsimile: (415) 421—1700
MATTHEW C. HELLAND (SBN 25045 1)
helland@nka.c0m
DANIEL BROME (SBN 278915)
dbrome@nka.com
NICHOLS KASTER, LLP
‘235 Montgomery Street, Suite 810
San Francisco, CA 94104
Telephone: (415) 277-7235
Facsimile: (415) 277-7238
Attorneys for Plaintiff
(Additional Counsel on next page)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
ALIDA MAZAREEGOS, PAULA CASE NO.: 20-CIV-04267
GONZALEZ, and JAIME AMAYA
STIPULATION AND ORDER AFTER
-
Plaintiffs, on behalf of themselves CASE MANAGEMENT CONFERENCE
and all others similarly situated, HEARING
.V- Judge: Hon. Nancy L. Fineman
-
VANGUARD CLEANING SYSTEMS, Dept-3 04
INC; RR FRANCHISING, INC, D/B/A‘
VANGUARD CLEANING SYSTEMS
0E SOUTHERN CALIFORNIA AND
23 D/B/A VANGUARD CLEANING
SYSTEMS 0E NORTHERN
CALIFORNIA; BUDDHA CAPITAL
CORPORATION, D/B/A VANGUARD
CLEANING SYSTEMS OF
SACRAMENTO, D/B/A VANGUARD
CLEANING SYSTEMS OF THE
CENTRAL VALLEY, AND D/B/A
VANGUARD CLEANING SYSTEMS
OF THE CENTRAL COAST; AND
STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING
WINE COUNTRY VENTURES, INC.
D/B/A VANGUARD CLEANING
SYSTEMS OF THE NORTH BAY,
AND DOES 1 THROUGH 10,
INCLUSIVE,
Defendants.
\OOOQONUI-hUJNr-i
OOxlmUl-AUJNHOKDOOQONUI-bUJNI—‘O
NNNNNNNNNr—HHHHHHHHH
STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING
‘\
\J/
,
\
/
DAMON M. OTT, Bar No. 215392
dott@1ittler.com
PHILIP B. BALDWIN, Bar No. 307920 '
pbaldwin@littler.com
LITTLER MENDELSON, P.C.
333 Bush Street
34th Floor
San Francisco, "CA 94104
Telephone: 4 l 5 .433. 1 940
Fax No.2 4 l 5.399.8490
Attorneys for Defendant
Vanguard Cleaning Systems, Inc.
Fraser A. McAlpine (State Bar No. 248554)
10 JACKSON LEWIS P.C.
50 California Street, 9th Floor
11 San Francisco, California 941 1 1-4615
12 Telephone: 415) 394-9400
Facsimile: (415) 394-9401
13 E—mail: Fraser.McAlpine@jacksonlewis.com
14 Attorneys for Defendants RR Franchising, Inc,
Buddha Capital Comoration and Wine Country Ventures, Inc.
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING
Plaintiffs Alida Mazariegos, Paula Gonzalez, and Jaime Amaya (“Plaintiffs”) and
Defendants Vanguard Cleaning Systems, Inc. (“Vanguard”); RR Franchising, Inc., d/b/a
Vanguard Cleaning Systems of Southern California and d/b/a Vanguard Cleaning Systems of
Northern California (“RR Franchising”); Buddha Capital Corporation, d/b/a/ Vanguard Cleaning
Systems’of Sacramento, d/b/a Vanguard Cleaning Systems of the Central Valley, and d/b/a/
Vanguard Cleaning Systems of the Central Coast (“Buddha Capital”); and Wine Country
Ventures, Inc. d/b/a Vanguard Cleaning Systems of the North Bay (“Wine Country”)
(“Defendants”) (collectively “the Parties”) stipulate as follows:
WHEREAS the Court held a case management conference on April 6, 2021 at 8:30 a.m.,
10 and this stipulation reects the matters discussed at the hearing;
11 WHEREAS the Parties scheduled an informal discovery conference (IDC) with the Court
12 regarding the issue of the release between Defendant Wine Country and Plaintiff Mazariegos;
13 WHEREAS the IDC is scheduled for April 15, 2021 at 9:00 a.m., with the Parties to
14 submit statements by email to Department 4 by April 13, 2021;
15 WHEREAS the Parties discussed potential dates, deadlines, and sequencing for future
16 motions, and the Court set dates for Plaintiffs’ motion for class certication—Plaintiffs shall le
17 their motion for class certication by August 6, 2021, Defendants shall le their opposition by
18 November 5, 2021, Plaintiffs shall le their reply by November l9, 2021 , and the hearing shall
i
19 be held on December 7, 2021 at 8:30 a.m.;
20 WHEREAS the Court also ordered the Parties to return for a further case management
‘21 conference on July 6, 2021 at 8:30 a.m. The Court further ordered that the Parties le a joint case
22 management conference statement by June 29, 2021.
23 NOW THEREFORE, the Parties, by and through their respective counsel, hereby
24 stipulate, subject to Court approval, as follows:
25 1. The Court will hold an informal discovery conference with the Parties regarding the
26 issue of the release between Plaintiff Mazariegos and Defendant Wine Country on
27 April 15, at 9:00 a.m., with statements to be emailed to Department 4 by April 13.
28 2. The brieng schedule for Plaintiffs’ motion for class certication shall be as follows:
l
STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARlNG
V—k
1/ \\ /
(
,1' x
Plaintiffs” motion for class certication shall be led by August 6, 2021.
Defendants’ by November 5, 2021.
Ix)
b. opposition shall be led
c. Plaintiffs’ reply shall be led by November 19, 202 1.
d. The hearing. date shall be December 7, 2021 at 8330 am.
3. The Court shall set a further case management conference on July 6, 2021 at 8:30 am.
The Parties shall le a joint case management conference statement by June 29, 2021.
Dated: May 14, 2021 RUKIN LLP
By:HYLD &%GIN
10 Valerie Brendel'
Jessica Riggin
11 .Attorneys for Plaintiffs
12
13 Dated: May 14, 2021 LITTLER MENDELSON P.C.
14
Byz/s/ Philip Baldwin
15
Philip Baldwin
Damon Ott
16 Attorneys for Defendant Vanguard Cleaning Systems, Inc.
17
18
Dated: May l4, 2021 JACKSON LEWIS P.C.
19
By: /s/ Fraser A. McAlpine
20 Fraser A. McAlpine
21 Attorneys for RR Franchising, Inc., Buddha Capital
Corporation, and Wine Country Ventures, Inc.
22
23
24
25
26
27
28
2
STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING
1
'
1;;
'
[PROPOSED] ORDER OF THE COURT
Pursuant to the stipulation of the parties, and GOOD CAUSE APPEARING, IT IS
HEREBY ORDERED THAT
1. An informal discovery conference with the Parties regarding the issue of the
release between PlaintiffMazariegos and Defendant Wine Country is set for April
15, at 9:00 am. The Parties shall email statements to Department 4 by April 13.
I
2. The brieng schedule for Plaintiffs’ motion for class certication shall be as
follows:
a. Plaintiffs’ motion for class certication shall be led by August 6, 2021.
10 b. Defendants’ opposition shall be led by November 5, 2021.
11 c. Plaintiffs’ reply shall be led by November 19, 2021.
12 d. The hearing date shall be December 7, 2021 at 8:30 a.m.
13 3. A further case management conference is set for July 6, 2021 at 8:30 a.m. The
14 Parties shall file a joint case‘management conference statement by June 29, 2021.
15
IT SO ORDERED.
16
17
Dated:
18
THE HONORABLE NANCY L. FINEMAN
19
Judge of the Superior Court
20
21
22
23
24
25
26
27
28
3
STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING
Preview
W JESSICA RIGGIN (SBN 28 1712) jrz'ggz'n@rukinhyland.com VALERIE BRENDER (SBN 298224) vbrender@rukinhyland.com RUKIN HYLAND & RIGGDI LLP 1939 Harrison Street, Suite 290 Oakland, CA 94612 Telephone: (415) 421-1800 Facsimile: (415) 421—1700 MATTHEW C. HELLAND (SBN 25045 1) helland@nka.c0m DANIEL BROME (SBN 278915) dbrome@nka.com NICHOLS KASTER, LLP ‘235 Montgomery Street, Suite 810 San Francisco, CA 94104 Telephone: (415) 277-7235 Facsimile: (415) 277-7238 Attorneys for Plaintiff (Additional Counsel on next page) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO ALIDA MAZAREEGOS, PAULA CASE NO.: 20-CIV-04267 GONZALEZ, and JAIME AMAYA STIPULATION AND ORDER AFTER - Plaintiffs, on behalf of themselves CASE MANAGEMENT CONFERENCE and all others similarly situated, HEARING .V- Judge: Hon. Nancy L. Fineman - VANGUARD CLEANING SYSTEMS, Dept-3 04 INC; RR FRANCHISING, INC, D/B/A‘ VANGUARD CLEANING SYSTEMS 0E SOUTHERN CALIFORNIA AND 23 D/B/A VANGUARD CLEANING SYSTEMS 0E NORTHERN CALIFORNIA; BUDDHA CAPITAL CORPORATION, D/B/A VANGUARD CLEANING SYSTEMS OF SACRAMENTO, D/B/A VANGUARD CLEANING SYSTEMS OF THE CENTRAL VALLEY, AND D/B/A VANGUARD CLEANING SYSTEMS OF THE CENTRAL COAST; AND STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING WINE COUNTRY VENTURES, INC. D/B/A VANGUARD CLEANING SYSTEMS OF THE NORTH BAY, AND DOES 1 THROUGH 10, INCLUSIVE, Defendants. \OOOQONUI-hUJNr-i OOxlmUl-AUJNHOKDOOQONUI-bUJNI—‘O NNNNNNNNNr—HHHHHHHHH STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING ‘\ \J/ , \ / DAMON M. OTT, Bar No. 215392 dott@1ittler.com PHILIP B. BALDWIN, Bar No. 307920 ' pbaldwin@littler.com LITTLER MENDELSON, P.C. 333 Bush Street 34th Floor San Francisco, "CA 94104 Telephone: 4 l 5 .433. 1 940 Fax No.2 4 l 5.399.8490 Attorneys for Defendant Vanguard Cleaning Systems, Inc. Fraser A. McAlpine (State Bar No. 248554) 10 JACKSON LEWIS P.C. 50 California Street, 9th Floor 11 San Francisco, California 941 1 1-4615 12 Telephone: 415) 394-9400 Facsimile: (415) 394-9401 13 E—mail: Fraser.McAlpine@jacksonlewis.com 14 Attorneys for Defendants RR Franchising, Inc, Buddha Capital Comoration and Wine Country Ventures, Inc. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING Plaintiffs Alida Mazariegos, Paula Gonzalez, and Jaime Amaya (“Plaintiffs”) and Defendants Vanguard Cleaning Systems, Inc. (“Vanguard”); RR Franchising, Inc., d/b/a Vanguard Cleaning Systems of Southern California and d/b/a Vanguard Cleaning Systems of Northern California (“RR Franchising”); Buddha Capital Corporation, d/b/a/ Vanguard Cleaning Systems’of Sacramento, d/b/a Vanguard Cleaning Systems of the Central Valley, and d/b/a/ Vanguard Cleaning Systems of the Central Coast (“Buddha Capital”); and Wine Country Ventures, Inc. d/b/a Vanguard Cleaning Systems of the North Bay (“Wine Country”) (“Defendants”) (collectively “the Parties”) stipulate as follows: WHEREAS the Court held a case management conference on April 6, 2021 at 8:30 a.m., 10 and this stipulation reects the matters discussed at the hearing; 11 WHEREAS the Parties scheduled an informal discovery conference (IDC) with the Court 12 regarding the issue of the release between Defendant Wine Country and Plaintiff Mazariegos; 13 WHEREAS the IDC is scheduled for April 15, 2021 at 9:00 a.m., with the Parties to 14 submit statements by email to Department 4 by April 13, 2021; 15 WHEREAS the Parties discussed potential dates, deadlines, and sequencing for future 16 motions, and the Court set dates for Plaintiffs’ motion for class certication—Plaintiffs shall le 17 their motion for class certication by August 6, 2021, Defendants shall le their opposition by 18 November 5, 2021, Plaintiffs shall le their reply by November l9, 2021 , and the hearing shall i 19 be held on December 7, 2021 at 8:30 a.m.; 20 WHEREAS the Court also ordered the Parties to return for a further case management ‘21 conference on July 6, 2021 at 8:30 a.m. The Court further ordered that the Parties le a joint case 22 management conference statement by June 29, 2021. 23 NOW THEREFORE, the Parties, by and through their respective counsel, hereby 24 stipulate, subject to Court approval, as follows: 25 1. The Court will hold an informal discovery conference with the Parties regarding the 26 issue of the release between Plaintiff Mazariegos and Defendant Wine Country on 27 April 15, at 9:00 a.m., with statements to be emailed to Department 4 by April 13. 28 2. The brieng schedule for Plaintiffs’ motion for class certication shall be as follows: l STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARlNG V—k 1/ \\ / ( ,1' x Plaintiffs” motion for class certication shall be led by August 6, 2021. Defendants’ by November 5, 2021. Ix) b. opposition shall be led c. Plaintiffs’ reply shall be led by November 19, 202 1. d. The hearing. date shall be December 7, 2021 at 8330 am. 3. The Court shall set a further case management conference on July 6, 2021 at 8:30 am. The Parties shall le a joint case management conference statement by June 29, 2021. Dated: May 14, 2021 RUKIN LLP By:HYLD &%GIN 10 Valerie Brendel' Jessica Riggin 11 .Attorneys for Plaintiffs 12 13 Dated: May 14, 2021 LITTLER MENDELSON P.C. 14 Byz/s/ Philip Baldwin 15 Philip Baldwin Damon Ott 16 Attorneys for Defendant Vanguard Cleaning Systems, Inc. 17 18 Dated: May l4, 2021 JACKSON LEWIS P.C. 19 By: /s/ Fraser A. McAlpine 20 Fraser A. McAlpine 21 Attorneys for RR Franchising, Inc., Buddha Capital Corporation, and Wine Country Ventures, Inc. 22 23 24 25 26 27 28 2 STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING 1 ' 1;; ' [PROPOSED] ORDER OF THE COURT Pursuant to the stipulation of the parties, and GOOD CAUSE APPEARING, IT IS HEREBY ORDERED THAT 1. An informal discovery conference with the Parties regarding the issue of the release between PlaintiffMazariegos and Defendant Wine Country is set for April 15, at 9:00 am. The Parties shall email statements to Department 4 by April 13. I 2. The brieng schedule for Plaintiffs’ motion for class certication shall be as follows: a. Plaintiffs’ motion for class certication shall be led by August 6, 2021. 10 b. Defendants’ opposition shall be led by November 5, 2021. 11 c. Plaintiffs’ reply shall be led by November 19, 2021. 12 d. The hearing date shall be December 7, 2021 at 8:30 a.m. 13 3. A further case management conference is set for July 6, 2021 at 8:30 a.m. The 14 Parties shall file a joint case‘management conference statement by June 29, 2021. 15 IT SO ORDERED. 16 17 Dated: 18 THE HONORABLE NANCY L. FINEMAN 19 Judge of the Superior Court 20 21 22 23 24 25 26 27 28 3 STIPULATION AND ORDER AFTER CASE MANAGEMENT CONFERENCE HEARING