Stipulation,Agreement: HUISAR -V- APPLIED BEHAVIOR (COMPLEX) Print

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                 1   VACHE A THOMASSIAN                 S B       289053                     F   L E D
                     C8S   ar c   kjtlaw   OU   COIYl                                SUPERIOR COURT OF CALIFORNIA
                                                                                      COUNTY OF SAN B RNARDINQ
                 2   CA PAR JNA AG AN S B                   282818                     SAN BERNAROINO DISTRICT
                     cas ar q kjtlaw roup corn
                 3   KJ  LAW GROUP LLP
                                                                                           JA N 13 2020
                     230 N Maryland Ave Suite 306
                 4   Glendale CA 91206
                     Telephone 818 507 8525                                       gy
        y
                 5
                     CHR ISTOPHER A ADAMS S B                     266440                 Al E G RVANTES DEPUTY
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                 6   ca q AdamsEmploym entCounsel com
                     ADAMS EMPLOYMENT COUNSEL
                 7   230 N Maryland Ave Suite 306
        r            Glendale CA 91206
                 8   Telephone        818 425 1437

                 9   Attorneys for Plaintiff Sulin Huisar

                10                              SUPERIOR COURT OF THE STATE OF CALIFORNIA

                11                                          COUNTY OF SAN BERNAROINO

                12   SULIN HUISAR                                          Case No     CN DS1909249
                                           individually     and   on


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                     behalf of all others similarly situated
            q                                                              Assigned forall purposes toJudge David Cohn
                                                Plaintiff                  Dept 5 26
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                              v                                            JOINT STIPULATION TO CONTINUE HEARING FOR
                15                                                         PRELIMINARY APPROVAL OF CLA55 ACTION
                     APPLIED BEHAVIOR                                      SETTIEMENT JRR6P63fB ORDER
                16   CONSULTANTS INC a corporation
                     and DOES 1 20 inclusive
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                                                Defendants
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                     JOINT STIPULATION TO CONTINUE HEARING FOR PRELIMINARY APPROVAL OF CLASS ACTION
                                                                       SETTLEMENT
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         1   TO THE COURT ALL PARTIES AND THEIR COUNSEL OF RECORD


         2            PLEASE TAKE NOTICE that Plaintiff Sulin Huisar   Plaintiff   and Defendant Applied

         3   Behavior Consultants Inc      Defendant     Plaintiff and Defendant collectively referred to
         4        the Parties
             as
                                by and through their respective counsel of record hereby enter into the
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             following Joint Stipulation to continue the Hearing for Preliminary Approval ofClass
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             Action Settlement currently set for January 14 2020 at 8 30 a m in Department 5 26 in
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             the above entitled Court to the earliest available hearing date after February 14 2020
         8            WHEREAS on March 26 2019 Plaintiff filed this class and representative lawsuit

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             asserting various wage and hour claims under the California Labor Code and Business
        10   and Professions Code

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                      WHEREAS after meeting and conferring Plaintiff and Defendant agreed to explore
        12   a resolution ofthis action through mediation

        13            WHEREAS to that end on October 31 2019 the Parties attended mediation and

g       14   were able to resolve this matter

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                      WHEREAS since then the Parties have been working together to prepare a
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             settlement agreement class notice and preliminary approval documents and
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                      WHEREAS unfortunately due to scheduling issues and the holidays the Parties
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             need additional time to finalize these documents and respectfully request that the Court
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             continue the approval hearing date to the earliest available hearing date after February
        20   14 2020

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                      NOW THEREFORE in consideration ofthe foregoing IT IS HEREBY STIPULATED by
        22   and between the Parties subject to the Court approval that

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                            1 he Hearing for Preliminary Approval of Class Action Settlement
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             currently set for January 14 2020 at 8 30 a m be continued to the earliest available
        25   hearing date after February 14 2020
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                                             Signatures on following page
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             JOINT STIPULATION TO CONTINUE HEARING FOR PRELIMINARY APPROVAL OF CLASS ACTION
                                                     SETTLEMENT
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