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1 DAVID YEREMIAN & ASSOCIATES, INC.
David Yeremian (SBN 226337)
2 David(2),veremianlaw.com
Jason Rothman (SBN 304961)
3 Jason(g),veremianlaw.com
535 N. Brand Blvd., Suite 705
4 Glendale, Califomia 91203
Telephone: (818) 230-8380
5
UNITED EMPLOYEES LAW GROUP, PC
6 Walter Haines (SBN 71075371300812301005
whaines@uelg.com
7 5500 Bolsa Ave., Suite 201
Huntington Beach, CA 92649
8 Telephone: (310) 652-242
9 Attomeys for Plaintiff Chia Xiong,
on behalf of herself and all others similarly situated
10
McKAGUE I ROSASCO LLP
11 Erica L. Rosasco (SBN 220836)
erica(3lmckaguerosasco.com
12 Dawn M. Berry (SBN 292335)
dawn@mckaguerosasco.com
13 1217 Pleasant Grove Blvd., Suite 120
Roseville, CA 95678
14 Telephone: (916) 672-6552
15 Attomeys for Defendant TGC Enterprises, Inc.
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF SACRAMENTO
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19
CHL\ XIONG, an individual, on behalf of Case No.:34-2020-00278650
20 herself and others similarly situated.
CLASS ACTION
21 Plaintiff,
[Assigned for all purposes to Hon. David De Alba]
22 vs.
JOINT STIPULATION TO CONTINUE
23 TGC ENTERPRISES, INC., a Califomia CASE MANAGEMENT CONFERENCE;
corporation; and DOES 1 through 50, inclusive, ^fBPOSED] ORDER
24
Defendants. Date: April 23,2021
25 Time: 10:00 a.m.
Dept.: 41
26
Complaint Filed: May 14, 2020
27 Trial Date: None Set
JOINT STIPULATION TO CONTINUE CASE MANAGEMENT C O N F E R E N C E ^ ^ ^ ^ ^ S S E D ^ ORDER
64
1 Plaintiff Chia Xiong ("Plaintiff) and Defendant TGC Enterprises, Inc. ("Defendant")
2 (collectively, the "Parties"), by and through their respective counsel of record, respectfully submit
3 the following Joint Stipulation to Continue the Parties' April 23, 2021 Case Management
4 Conference:
WHEREAS, following the Court's initial Case Management Conference on December 3,
5
2020, Defendant provided its financial records to Plaintiff pursuant to a stipulated protective
6
order;
7
WHEREAS, Plaintiff and her counsel are in the process of reviewmg those records with
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their financial experts; and
9
WHEREAS, in order to allow Plaintiff sufficient time to complete her review of
10
Defendant's financial records and to allow the Parties time to explore an informal resolution of
11
Plaintiffs claims, the Parties wish to continue the April 23, 2021 Case Management Conference
12 by approximately 90 days.
13 NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties, and
14 respectfully requested, that the Court continue the Parties' April 23, 2021 Case Management
15 Conference to July 23, 2021 at 10:00 a.m., or as soon thereafter as is convenient for the Court.
16 IT IS SO STIPULATED.
17 DATED: April 12, 2021 DAVID YEREMIAN & ASSOCIATES, INC.
18
19 Bv Is/ Jason Rothman
Jason Rothman
20 Attomeys for Plaintiff
21
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DATED: April 12, 2021 McKAGUE I ROSASCO LLP
23
24
By /s/ Dawn M. Berry
25 Dawn M. Berry
Attomeys for Defendant
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JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
1 IPROPOSEDI ORDER
2 The Court, having read and considered the Parties' Joint Stipulation to Continue the
3 Parties' April 23, 2021 Case Management Conference, and for GOOD CAUSE shown, hereby
4 ORDERS as follows:
5 1. The Case Management Conference set for April 23, 2021 at 10:00 a.m. is hereby
continued to:
6
July 23, 2021 at LOiflO-ftrmr-
7
• at a.m./p.m.
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2. The Parties are ordered to submit Case Management Statements no later than 15 days
9
prior to the continued Case Management Conference.
10
IT IS SO ORDERED.
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12 Dated: ^ / / ^ / R O ^ }
fabl6
13
3ge of the Superior Court
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II ^ f j ^ I - .
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•2-
JODSfT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
PROOF OF SERVICE
I
Chia Xiong v. TGC Enterprises, Inc.
2
Sacramento County Superior Court Case No. 34-2020-00278650
3
I am over the age of eighteen years and not a party to the within above-entitled action. I am
4 an employee of McKague Rosasco LLP, and my business address is 1217 Pleasant Grove
Boulevard, Suite 120, Roseville, CA 95678.
5
On this date, April 12, 2021,1 caused to be served the within document(s)
6
JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE;
7 [PROPOSED] ORDER
8 on the parties in said action addressed as follows:
9
David Yeremian
10 Jason Rothman
11 DAVID YEREMIAN & ASSOCIATES, INC.
535 N. Brand Blvd., Suite 705
12 Glendale, CA 91203
13 Walter Haines
14 UNITED EMPLOYEES LAW GROUP, PC
5500 Bolsa Ave., Suite 201
15 Huntington Beach, CA 92649
Attorneys for Plaintiff
16
17 (x) [By Mail] I am familiar with my employer's practice for the collecting and processing of
correspondence for mailing with the United States Postal Service and that each day's mail
18 is deposited in the ordinary course of business. On the date set forth above, I served the
aforementioned document(s) on the parties in said action, addressed as set forth above, by
19 placing a tme copy in a sealed envelope with First Class postage fully prepaid, at Roseville,
20 CA.
21 0 [By Facsimile] I faxed the document(s) to the person(s) at the fax number(s) listed in the
service list. The telephone number of the sending facsimile machine is (916) 672-6563.
22 The sending facsimile machine issued a transmission report confirming that the
transmission was complete and without error.
23
0 [By Electronic Mail] I caused said document(s) to be sent via electronic mail to the
24 addressee(s) at the email address(es) listed above.
25 I declare under penalty of perjury under the laws of the State of Califomia that the foregoing
26 is tme and correct, and that this declaration was executed on April 12, 2021, at Roseville, CA.
27 /s/ Samantha Paddock
28 Samantha Paddock
1
PROOF OF SERVICE
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1 DAVID YEREMIAN & ASSOCIATES, INC. David Yeremian (SBN 226337) 2 David(2),veremianlaw.com Jason Rothman (SBN 304961) 3 Jason(g),veremianlaw.com 535 N. Brand Blvd., Suite 705 4 Glendale, Califomia 91203 Telephone: (818) 230-8380 5 UNITED EMPLOYEES LAW GROUP, PC 6 Walter Haines (SBN 71075371300812301005 whaines@uelg.com 7 5500 Bolsa Ave., Suite 201 Huntington Beach, CA 92649 8 Telephone: (310) 652-242 9 Attomeys for Plaintiff Chia Xiong, on behalf of herself and all others similarly situated 10 McKAGUE I ROSASCO LLP 11 Erica L. Rosasco (SBN 220836) erica(3lmckaguerosasco.com 12 Dawn M. Berry (SBN 292335) dawn@mckaguerosasco.com 13 1217 Pleasant Grove Blvd., Suite 120 Roseville, CA 95678 14 Telephone: (916) 672-6552 15 Attomeys for Defendant TGC Enterprises, Inc. 16 SUPERIOR COURT OF THE STATE OF CALIFORNIA 17 FOR THE COUNTY OF SACRAMENTO 18 19 CHL\ XIONG, an individual, on behalf of Case No.:34-2020-00278650 20 herself and others similarly situated. CLASS ACTION 21 Plaintiff, [Assigned for all purposes to Hon. David De Alba] 22 vs. JOINT STIPULATION TO CONTINUE 23 TGC ENTERPRISES, INC., a Califomia CASE MANAGEMENT CONFERENCE; corporation; and DOES 1 through 50, inclusive, ^fBPOSED] ORDER 24 Defendants. Date: April 23,2021 25 Time: 10:00 a.m. Dept.: 41 26 Complaint Filed: May 14, 2020 27 Trial Date: None Set JOINT STIPULATION TO CONTINUE CASE MANAGEMENT C O N F E R E N C E ^ ^ ^ ^ ^ S S E D ^ ORDER 64 1 Plaintiff Chia Xiong ("Plaintiff) and Defendant TGC Enterprises, Inc. ("Defendant") 2 (collectively, the "Parties"), by and through their respective counsel of record, respectfully submit 3 the following Joint Stipulation to Continue the Parties' April 23, 2021 Case Management 4 Conference: WHEREAS, following the Court's initial Case Management Conference on December 3, 5 2020, Defendant provided its financial records to Plaintiff pursuant to a stipulated protective 6 order; 7 WHEREAS, Plaintiff and her counsel are in the process of reviewmg those records with 8 their financial experts; and 9 WHEREAS, in order to allow Plaintiff sufficient time to complete her review of 10 Defendant's financial records and to allow the Parties time to explore an informal resolution of 11 Plaintiffs claims, the Parties wish to continue the April 23, 2021 Case Management Conference 12 by approximately 90 days. 13 NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties, and 14 respectfully requested, that the Court continue the Parties' April 23, 2021 Case Management 15 Conference to July 23, 2021 at 10:00 a.m., or as soon thereafter as is convenient for the Court. 16 IT IS SO STIPULATED. 17 DATED: April 12, 2021 DAVID YEREMIAN & ASSOCIATES, INC. 18 19 Bv Is/ Jason Rothman Jason Rothman 20 Attomeys for Plaintiff 21 22 DATED: April 12, 2021 McKAGUE I ROSASCO LLP 23 24 By /s/ Dawn M. Berry 25 Dawn M. Berry Attomeys for Defendant 26 27 28 JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER 1 IPROPOSEDI ORDER 2 The Court, having read and considered the Parties' Joint Stipulation to Continue the 3 Parties' April 23, 2021 Case Management Conference, and for GOOD CAUSE shown, hereby 4 ORDERS as follows: 5 1. The Case Management Conference set for April 23, 2021 at 10:00 a.m. is hereby continued to: 6 July 23, 2021 at LOiflO-ftrmr- 7 • at a.m./p.m. 8 2. The Parties are ordered to submit Case Management Statements no later than 15 days 9 prior to the continued Case Management Conference. 10 IT IS SO ORDERED. 11 12 Dated: ^ / / ^ / R O ^ } fabl6 13 3ge of the Superior Court 14 15 16 II ^ f j ^ I - . 17 18 19 20 21 22 23 24 25 26 27 28 •2- JODSfT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER PROOF OF SERVICE I Chia Xiong v. TGC Enterprises, Inc. 2 Sacramento County Superior Court Case No. 34-2020-00278650 3 I am over the age of eighteen years and not a party to the within above-entitled action. I am 4 an employee of McKague Rosasco LLP, and my business address is 1217 Pleasant Grove Boulevard, Suite 120, Roseville, CA 95678. 5 On this date, April 12, 2021,1 caused to be served the within document(s) 6 JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; 7 [PROPOSED] ORDER 8 on the parties in said action addressed as follows: 9 David Yeremian 10 Jason Rothman 11 DAVID YEREMIAN & ASSOCIATES, INC. 535 N. Brand Blvd., Suite 705 12 Glendale, CA 91203 13 Walter Haines 14 UNITED EMPLOYEES LAW GROUP, PC 5500 Bolsa Ave., Suite 201 15 Huntington Beach, CA 92649 Attorneys for Plaintiff 16 17 (x) [By Mail] I am familiar with my employer's practice for the collecting and processing of correspondence for mailing with the United States Postal Service and that each day's mail 18 is deposited in the ordinary course of business. On the date set forth above, I served the aforementioned document(s) on the parties in said action, addressed as set forth above, by 19 placing a tme copy in a sealed envelope with First Class postage fully prepaid, at Roseville, 20 CA. 21 0 [By Facsimile] I faxed the document(s) to the person(s) at the fax number(s) listed in the service list. The telephone number of the sending facsimile machine is (916) 672-6563. 22 The sending facsimile machine issued a transmission report confirming that the transmission was complete and without error. 23 0 [By Electronic Mail] I caused said document(s) to be sent via electronic mail to the 24 addressee(s) at the email address(es) listed above. 25 I declare under penalty of perjury under the laws of the State of Califomia that the foregoing 26 is tme and correct, and that this declaration was executed on April 12, 2021, at Roseville, CA. 27 /s/ Samantha Paddock 28 Samantha Paddock 1 PROOF OF SERVICE