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1 CDF LABOR LAW LLP
Nicole A. Legrottaglie, State Bar No. 271416
2 nlegrottaglie@cdflaborlaw.com
Tashayla D. Billington, State Bar No. 307050
3 tbillington@cdflaborlaw.com
900 University Avenue, Suite 200
4 Sacramento, CA 95825
Telephone: (916) 361-0991
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Attorneys for Defendants ACADIA HEALTHCARE
6 COMPANY, INC., DUFFY’S NAPA VALLEY REHAB, LLC
7 Larry M. Kazanjian, SBN: 71441
Casey M. Blanas, SBN: 296447
8 PALMER KAZANJIAN WOHL HODSON LLP
2277 Fair Oaks Boulevard, Suite 455
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Sacramento, CA 95825
10 Telephone: (916) 442-3552
Facsimile: (916) 640-1521
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Attorneys for Defendant MAREN VICK
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13 SUPERIOR COURT OF THE STATE OF CALIFORNIA
14 COUNTY OF NAPA
15 SCOTT FLOODMAN, an individual, ) Case No. 21CV001089
)
16 Plaintiff, ) STIPULATION AND [PROPOSED]
vs. ) ORDER TO CONTINUE CASE
17 ) MANAGEMENT CONFERENCE
ACADIA HEALTHCARE COMPANY, INC., )
18 a Delaware corporation; DUFFY’S NAPA ) Date: December 7, 2022
VALLEY REHAB, LLC, a Delaware limited ) Time: 8:30 a.m.
19 liability company; MAREN VICK, an ) Ctrm: B
individual; and DOES 1 through 100, inclusive, )
20 ) Action Filed: July 29, 2021
Defendants. )
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STIPULATION AND [PROPOSED] ORDER TO
CDF LABOR LAW LLP CONTINUE CASE MANAGEMENT
CONFERENCE
2082993.1
1 This Stipulation is entered into by and between Defendants Acadia Healthcare Company,
2 Inc., Duffy’s Napa Valley Rehab, LLC and Maren Vick (“Defendants”) and (together referred to
3 herein as the “Parties”), by and through their respective counsel of record, who hereby stipulate as
4 follows:
5 WHEREAS, a Case Management Conference is currently scheduled for December 7, 2022
6 at 8:30 a.m. in Courtroom B.
7 WHEREAS, this Court’s ruling on the Motion to Compel Arbitration the parties are
8 compelled to arbitrate Plaintiff’s claims.
9 WHEREAS, on this basis, the Parties request a continuance of the upcoming December 7,
10 2022 case management conference until sixty (60) days after the parties’ Arbitration, scheduled to
11 complete December 2, 2022 or such later dates and/or time as may be set by the Court.
12 WHEREAS, good cause exists to grant the requested continuance to preserve the resources
13 of the Parties and the Court.
14 WHEREAS, the Parties have not requested any prior continuances of any other deadlines in
15 this case. By granting the requested continuance, there will be no prejudice to the Parties or the
16 putative class members.
17 NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, subject to the
18 approval of the Court, that the December 7, 2022 Case Management Conference be continued until
19 ninety (90) days after the parties’ Arbitration, scheduled to complete December 2, 2022 such later
20 dates and/or time as may be set by the Court.
21 IT IS SO STIPULATED.
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23 Dated: November 23, 2022 CDF LABOR LAW LLP
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25 By:
Tashayla Billington
26 Attorneys for Defendants
ACADIA HEALTHCARE COMPANY, INC., DUFFY’S
27 NAPA VALLEY REHAB, LLC
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2 STIPULATION AND [PROPOSED] ORDER TO
CDF LABOR LAW LLP CONTINUE CASE MANAGEMENT
CONFERENCE
2082993.1
1 Dated: November ___, 21 2022 PALMER KAZANJIAN WOHL HODSON LLP
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3 By:
Larry M. Kazanjian
4 Casey M. Blanas
Attorneys for Defendant
5 MAREN VICK
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3 JOINT STIPULATION AND [PROPOSED]
CDF LABOR LAW LLP ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE
2082993.1
1 [PROPOSED] ORDER
2 Pursuant to the stipulation of the parties, and GOOD CAUSE APPEARING, IT IS
3 ORDERED, ADJUDGED AND DECREED, as follows:
4 The Case Management Conference hearing set for December 7, 2022, shall be vacated and
5 continued to ______________, 2023 at in Courtroom B.
6 IT IS SO ORDERED.
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8 DATED: ________________, 2022 __________________________________
Hon. Scott R.L. Young
9 Judge for the Superior Court
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4 STIPULATION AND [PROPOSED] ORDER TO
CDF LABOR LAW LLP CONTINUE CASE MANAGEMENT
CONFERENCE
2082993.1
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3 PROOF OF SERVICE
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5 STATE OF CALIFORNIA, COUNTY OF SACRAMENTO.
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I, the undersigned, declare that I am employed in the aforesaid County, State of California.
7 I am over the age of 18 and not a party to the within action. My business address is 900 University
Avenue, Suite 200, Sacramento, CA 95825. On November 23, 2022, I served upon the interested
8 party(ies) in this action the following document described as:
9 STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE
10
By the following method:
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12 Kyle Todd Casey Blanas
Alfredo Nava Palmer Kazanjian Wohl Hodson LLP
13 KYLE TODD, P.C. 2277 Fair Oaks Blvd., Suite 455
611 Wilshire Blvd., Suite 315 Sacramento, CA 95825
14 Los Angeles, CA 90017
E-MAIL: cblanas@pkwhlaw.com;
15 E-MAIL: kyle@kyletodd.com; sragusa@pkwhlaw.com)
anava@kyletodd.com;
16 mmocciaro@kyletodd.com;
ffareed@kyletodd.com;
17 mgarcia@kyletodd.com
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19 □X (Agreement of Parties) Based on agreement of the parties to accept service by electronic
transmission, I caused the documents to be sent to the persons at the electronic notification
addresses listed above.
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I declare under penalty of perjury under the laws of the State of California that the
21 foregoing is true and correct.
22 Executed on November 23, 2022, at Sacramento, California.
23
Elizabeth P. Kastern
24 (Type or print name) (Signature)
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5 STIPULATION AND [PROPOSED] ORDER TO
CDF LABOR LAW LLP CONTINUE CASE MANAGEMENT
CONFERENCE
2082993.1
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1 CDF LABOR LAW LLP Nicole A. Legrottaglie, State Bar No. 271416 2 nlegrottaglie@cdflaborlaw.com Tashayla D. Billington, State Bar No. 307050 3 tbillington@cdflaborlaw.com 900 University Avenue, Suite 200 4 Sacramento, CA 95825 Telephone: (916) 361-0991 5 Attorneys for Defendants ACADIA HEALTHCARE 6 COMPANY, INC., DUFFY’S NAPA VALLEY REHAB, LLC 7 Larry M. Kazanjian, SBN: 71441 Casey M. Blanas, SBN: 296447 8 PALMER KAZANJIAN WOHL HODSON LLP 2277 Fair Oaks Boulevard, Suite 455 9 Sacramento, CA 95825 10 Telephone: (916) 442-3552 Facsimile: (916) 640-1521 11 Attorneys for Defendant MAREN VICK 12 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 COUNTY OF NAPA 15 SCOTT FLOODMAN, an individual, ) Case No. 21CV001089 ) 16 Plaintiff, ) STIPULATION AND [PROPOSED] vs. ) ORDER TO CONTINUE CASE 17 ) MANAGEMENT CONFERENCE ACADIA HEALTHCARE COMPANY, INC., ) 18 a Delaware corporation; DUFFY’S NAPA ) Date: December 7, 2022 VALLEY REHAB, LLC, a Delaware limited ) Time: 8:30 a.m. 19 liability company; MAREN VICK, an ) Ctrm: B individual; and DOES 1 through 100, inclusive, ) 20 ) Action Filed: July 29, 2021 Defendants. ) 21 ) 22 23 24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER TO CDF LABOR LAW LLP CONTINUE CASE MANAGEMENT CONFERENCE 2082993.1 1 This Stipulation is entered into by and between Defendants Acadia Healthcare Company, 2 Inc., Duffy’s Napa Valley Rehab, LLC and Maren Vick (“Defendants”) and (together referred to 3 herein as the “Parties”), by and through their respective counsel of record, who hereby stipulate as 4 follows: 5 WHEREAS, a Case Management Conference is currently scheduled for December 7, 2022 6 at 8:30 a.m. in Courtroom B. 7 WHEREAS, this Court’s ruling on the Motion to Compel Arbitration the parties are 8 compelled to arbitrate Plaintiff’s claims. 9 WHEREAS, on this basis, the Parties request a continuance of the upcoming December 7, 10 2022 case management conference until sixty (60) days after the parties’ Arbitration, scheduled to 11 complete December 2, 2022 or such later dates and/or time as may be set by the Court. 12 WHEREAS, good cause exists to grant the requested continuance to preserve the resources 13 of the Parties and the Court. 14 WHEREAS, the Parties have not requested any prior continuances of any other deadlines in 15 this case. By granting the requested continuance, there will be no prejudice to the Parties or the 16 putative class members. 17 NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, subject to the 18 approval of the Court, that the December 7, 2022 Case Management Conference be continued until 19 ninety (90) days after the parties’ Arbitration, scheduled to complete December 2, 2022 such later 20 dates and/or time as may be set by the Court. 21 IT IS SO STIPULATED. 22 23 Dated: November 23, 2022 CDF LABOR LAW LLP 24 25 By: Tashayla Billington 26 Attorneys for Defendants ACADIA HEALTHCARE COMPANY, INC., DUFFY’S 27 NAPA VALLEY REHAB, LLC 28 2 STIPULATION AND [PROPOSED] ORDER TO CDF LABOR LAW LLP CONTINUE CASE MANAGEMENT CONFERENCE 2082993.1 1 Dated: November ___, 21 2022 PALMER KAZANJIAN WOHL HODSON LLP 2 3 By: Larry M. Kazanjian 4 Casey M. Blanas Attorneys for Defendant 5 MAREN VICK 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JOINT STIPULATION AND [PROPOSED] CDF LABOR LAW LLP ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE 2082993.1 1 [PROPOSED] ORDER 2 Pursuant to the stipulation of the parties, and GOOD CAUSE APPEARING, IT IS 3 ORDERED, ADJUDGED AND DECREED, as follows: 4 The Case Management Conference hearing set for December 7, 2022, shall be vacated and 5 continued to ______________, 2023 at in Courtroom B. 6 IT IS SO ORDERED. 7 8 DATED: ________________, 2022 __________________________________ Hon. Scott R.L. Young 9 Judge for the Superior Court 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 STIPULATION AND [PROPOSED] ORDER TO CDF LABOR LAW LLP CONTINUE CASE MANAGEMENT CONFERENCE 2082993.1 1 2 3 PROOF OF SERVICE 4 5 STATE OF CALIFORNIA, COUNTY OF SACRAMENTO. 6 I, the undersigned, declare that I am employed in the aforesaid County, State of California. 7 I am over the age of 18 and not a party to the within action. My business address is 900 University Avenue, Suite 200, Sacramento, CA 95825. On November 23, 2022, I served upon the interested 8 party(ies) in this action the following document described as: 9 STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE 10 By the following method: 11 12 Kyle Todd Casey Blanas Alfredo Nava Palmer Kazanjian Wohl Hodson LLP 13 KYLE TODD, P.C. 2277 Fair Oaks Blvd., Suite 455 611 Wilshire Blvd., Suite 315 Sacramento, CA 95825 14 Los Angeles, CA 90017 E-MAIL: cblanas@pkwhlaw.com; 15 E-MAIL: kyle@kyletodd.com; sragusa@pkwhlaw.com) anava@kyletodd.com; 16 mmocciaro@kyletodd.com; ffareed@kyletodd.com; 17 mgarcia@kyletodd.com 18 19 □X (Agreement of Parties) Based on agreement of the parties to accept service by electronic transmission, I caused the documents to be sent to the persons at the electronic notification addresses listed above. 20 I declare under penalty of perjury under the laws of the State of California that the 21 foregoing is true and correct. 22 Executed on November 23, 2022, at Sacramento, California. 23 Elizabeth P. Kastern 24 (Type or print name) (Signature) 25 26 27 28 5 STIPULATION AND [PROPOSED] ORDER TO CDF LABOR LAW LLP CONTINUE CASE MANAGEMENT CONFERENCE 2082993.1