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1 LAW OFFICES OF DEBORAH F. BIRNDORF, APC
DEBORAH F. BIRNDORF, State BarNo. 179823
2 11845 W. Olympic Blvd., Suite 735W
Los Angeles, Califomia 90064
3 Telephone: (310)914-8400
Facsimile: (310) 914-8480
4 Email: DBirndorfCtfjBirndorfLaw.com
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Attomeys for Defendant
6 NEXTGEN LABORATORIES, INC.
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SACRAMENTO
10 ALEEZA KHAN, an individual and on behalf of CASE NO. 34-2022-00319499-CU-OE-
all others similarly situated. GDS
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12 Plaintiff, STIPULATION AND [PROPOSED]
ORDER R E : RESCHEDULING
13 vs. CASE MANAGEMENT
CONFERENCE
14 NEXTGEN LABORATORIES, INC., a
Califomia corporation.
15 [Assigned to the Honorable Jill Talley,
Defendants. Complex Civil Dept. 27]
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17 PQ
Action Filed: May 6, 2022
18 Trial Date: None
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STIPULATION AND [PROPOSED] ORDER RE: RESCHEDULING CASE MANAGEMENT
CONFERENCE
1 STIPULATION
2 TO THIS HONORABLE COURT:
3 1. WHEREAS, Plaintiff ALEEZA KHAN, filed a Complauit on or about May 6,
4 2022;
5 2. WHEREAS, a Notice of Acknowledgement of Receipt - Civil was signed between
6 the parties on July 25, 2022;
7 3. WHEREAS, Defendant NEXTGEN LABORATORIES, INC. filed a Notice of
8 Appearance on August 24, 2022;
9 4. WHEREAS, Defendant NEXTGEN LABORATORIES, INC. filed an Answer to
10 the Complaint on September 26, 2022;
11 5. WHEREAS, the parties filed a Joint Case Management Statement on January 25,
12 2023;
13 6. WHEREAS, the Court held a Case Management Conference for Febmary 9,2023,
14 whereat the Court scheduled a fiirther Case Management Conference for June 1,2023 at 1:30 p.m.
15 in Department 27.
16 7. WHEREAS, Defendant's coimsel is not available on June 1, 2023 (due to a family
17 obligation out of the country) and will not retum until June 6, 2023;
18 8. WHEREAS, both parties agree and stipulate to reschedule the Case Management
19 Conference from June 1,2023, to June 29, July 6, or June 22, 2023 (in order of preference), or any
20 subsequent date that is convenient for the Court;
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STIPULATION AND [PROPOSEDl ORDER RE: RESCHEDULING CASE MANAGEMENT
CONFERENCE
1 NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED that.
2 The Case Management Conference currentiy scheduled for June 1, 2023, be continued to
3 June 29, July 6, or June 22,2023 (in order of preference), or any subsequent date that is convenient
4 for the Court,
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DATED: March 6,2023 LAW OFFICES OF DEBORAH F. BIRNDORF, A PC
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By:
8 Deborah F. Bimdorf
Attomeys for Defendant
9 NEXTGEN LABORATORIES, INC
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11 DATED: March ^ . 2023 BASHAM LAW GROUP
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13 By:
Gary R. Basham
14 Attomeys for Plaintiff
ALEEZA KHAN
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STIPULATION AND [PROPOSED] ORDER RE: RESCHEDULING CASE MANAGEMENT
CONFERENCE
1 [PROPOSEDl ORDER
2 The Case Management Conference in the above-entitied matter, currently scheduled for
3 June 1, 2023, will be continued to , 2023.
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5 IT IS SO ORDERED:
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DATED: March ,2023
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JUDGE OF THE SUPERIOR COURT
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[PROPOSED] ORDER RE: RESCHEDULING CASE MANAGEMENT STATEMENT
PROOF OF SERVICE
2 I am employed in the county of Los Angeles, State of Califomia. I am over the age of 18
and not a party to the within action. My business address is 11845 W. Olympic Blvd., Suite
3 735W, Los Angeles, Califomia 90064.
4 On March 6,2023,1 served the following document(s) described as STIPULATION AND
[PROPOSED] ORDER RE: RESCHEDULING CASE MANAGEMENT CONFERENCE
5 on the interested parties in this action by attaching a tme and correct copy to the emails addressed
as follows:
6
GARY R. BASHAM
7 BASHAM LAW GROUP
8801 Folsom Blvd., Suite 280
8 Sacramento, CA 95826
Telephone: (916) 282-0841
9 Facsimile: (916) 266-7478
fjai~vfe"),basliamlawgroup.com
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Attomey for Plaintiff, ALEEZA KHAN an
11 individual and on behalf of all others
similarly situated
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m BY E-MAIL OR ELECTRONIC TRANSMISSION: In accordance with Califomia
13 Rules of Court, Rule 2.251(c) and Judicial Council Emergency Rule 12,1 caused a copy of
the document(s) to be sent from email address IVfonicaSmith(a),BimdorfLaw.com.
14 DTicvino@BirndorlLaw.com or DBirndorfCaiBirndorfLaw.com to the persons at the e-
mail addresses listed in the Service List. I did not receive, within reasonable time after
15 transmission, any electronic message or other indication that the transmission was
unsuccessfiil.
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I declare under penalty of peijury under the laws ofthe State of Califomia that the
17 foregoing is tme and correct.
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Executed on March 6, 2023, at Los Angeles, Califomia.
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21 Monica Smith
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PROOF OF SERVICE
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1 LAW OFFICES OF DEBORAH F. BIRNDORF, APC DEBORAH F. BIRNDORF, State BarNo. 179823 2 11845 W. Olympic Blvd., Suite 735W Los Angeles, Califomia 90064 3 Telephone: (310)914-8400 Facsimile: (310) 914-8480 4 Email: DBirndorfCtfjBirndorfLaw.com 5 Attomeys for Defendant 6 NEXTGEN LABORATORIES, INC. 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SACRAMENTO 10 ALEEZA KHAN, an individual and on behalf of CASE NO. 34-2022-00319499-CU-OE- all others similarly situated. GDS 11 12 Plaintiff, STIPULATION AND [PROPOSED] ORDER R E : RESCHEDULING 13 vs. CASE MANAGEMENT CONFERENCE 14 NEXTGEN LABORATORIES, INC., a Califomia corporation. 15 [Assigned to the Honorable Jill Talley, Defendants. Complex Civil Dept. 27] 16 17 PQ Action Filed: May 6, 2022 18 Trial Date: None 19 20 21 22 23 24 25 26 STIPULATION AND [PROPOSED] ORDER RE: RESCHEDULING CASE MANAGEMENT CONFERENCE 1 STIPULATION 2 TO THIS HONORABLE COURT: 3 1. WHEREAS, Plaintiff ALEEZA KHAN, filed a Complauit on or about May 6, 4 2022; 5 2. WHEREAS, a Notice of Acknowledgement of Receipt - Civil was signed between 6 the parties on July 25, 2022; 7 3. WHEREAS, Defendant NEXTGEN LABORATORIES, INC. filed a Notice of 8 Appearance on August 24, 2022; 9 4. WHEREAS, Defendant NEXTGEN LABORATORIES, INC. filed an Answer to 10 the Complaint on September 26, 2022; 11 5. WHEREAS, the parties filed a Joint Case Management Statement on January 25, 12 2023; 13 6. WHEREAS, the Court held a Case Management Conference for Febmary 9,2023, 14 whereat the Court scheduled a fiirther Case Management Conference for June 1,2023 at 1:30 p.m. 15 in Department 27. 16 7. WHEREAS, Defendant's coimsel is not available on June 1, 2023 (due to a family 17 obligation out of the country) and will not retum until June 6, 2023; 18 8. WHEREAS, both parties agree and stipulate to reschedule the Case Management 19 Conference from June 1,2023, to June 29, July 6, or June 22, 2023 (in order of preference), or any 20 subsequent date that is convenient for the Court; 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 STIPULATION AND [PROPOSEDl ORDER RE: RESCHEDULING CASE MANAGEMENT CONFERENCE 1 NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED that. 2 The Case Management Conference currentiy scheduled for June 1, 2023, be continued to 3 June 29, July 6, or June 22,2023 (in order of preference), or any subsequent date that is convenient 4 for the Court, 5 DATED: March 6,2023 LAW OFFICES OF DEBORAH F. BIRNDORF, A PC 6 7 By: 8 Deborah F. Bimdorf Attomeys for Defendant 9 NEXTGEN LABORATORIES, INC 10 11 DATED: March ^ . 2023 BASHAM LAW GROUP 12 13 By: Gary R. Basham 14 Attomeys for Plaintiff ALEEZA KHAN 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER RE: RESCHEDULING CASE MANAGEMENT CONFERENCE 1 [PROPOSEDl ORDER 2 The Case Management Conference in the above-entitied matter, currently scheduled for 3 June 1, 2023, will be continued to , 2023. 4 5 IT IS SO ORDERED: 6 DATED: March ,2023 7 JUDGE OF THE SUPERIOR COURT 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I [PROPOSED] ORDER RE: RESCHEDULING CASE MANAGEMENT STATEMENT PROOF OF SERVICE 2 I am employed in the county of Los Angeles, State of Califomia. I am over the age of 18 and not a party to the within action. My business address is 11845 W. Olympic Blvd., Suite 3 735W, Los Angeles, Califomia 90064. 4 On March 6,2023,1 served the following document(s) described as STIPULATION AND [PROPOSED] ORDER RE: RESCHEDULING CASE MANAGEMENT CONFERENCE 5 on the interested parties in this action by attaching a tme and correct copy to the emails addressed as follows: 6 GARY R. BASHAM 7 BASHAM LAW GROUP 8801 Folsom Blvd., Suite 280 8 Sacramento, CA 95826 Telephone: (916) 282-0841 9 Facsimile: (916) 266-7478 fjai~vfe"),basliamlawgroup.com 10 Attomey for Plaintiff, ALEEZA KHAN an 11 individual and on behalf of all others similarly situated 12 m BY E-MAIL OR ELECTRONIC TRANSMISSION: In accordance with Califomia 13 Rules of Court, Rule 2.251(c) and Judicial Council Emergency Rule 12,1 caused a copy of the document(s) to be sent from email address IVfonicaSmith(a),BimdorfLaw.com. 14 DTicvino@BirndorlLaw.com or DBirndorfCaiBirndorfLaw.com to the persons at the e- mail addresses listed in the Service List. I did not receive, within reasonable time after 15 transmission, any electronic message or other indication that the transmission was unsuccessfiil. 16 I declare under penalty of peijury under the laws ofthe State of Califomia that the 17 foregoing is tme and correct. 18 Executed on March 6, 2023, at Los Angeles, Califomia. 19 20 21 Monica Smith 22 23 24 25 26 27 28 1 PROOF OF SERVICE