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HATHAWAY, PERRETT, WEBSTER,
POWERS, CHRISMAN & GUTIERREZ, APC
ENDbR'SED
2 Alejandro P. Gutierrez: SBN 107688 2019 APR -8 PM 3: 53
agutierrez(^hathawayl a wfirm. com
3 5450 Telegraph Road, Suite 200 SAC^; A H t N l O COURTS
DEPT. /;5U
Ventura, CA 93003
4 Tel: (805) 644-7111; Fax: (805) 644-8296
5 Attomeys for Plaintiff, JOHN BOUDREAU,
6 individually, and on behalf of the Proposed Class
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF SACRAMENTO (UNLIMITED-COMPLEX)
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11 JOHN BOUDREAU, an individual, on behalf CASENO.: 34-2018-00247272
of himself and all others similarly situated, Assign^^to: Dept. 14
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Plaintiffs, [PftePOiSfeD] ORDER RE LEAVE TO
13 vs. F I L E FIRST AMENDED COMPLAINT
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PRIMERITUS FINANCIAL SERVICES, - -
15 INC., a Delaware corporation; CHRIS
McGINNESS, an individual; and DOES 1
16 through 10, inclusive.
17 Defendants.
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21 By and through the Stipulation by Plaintiff, John Boudreau, individually and on behalf of
22 the Proposed Class, and Defendants Primeritus Financial Services Inc. and Chris McGinness, and
23 upon reading and considering the Stipulation for Leave to File First Amended Complaint, and
24 GOOD CAUSE APPEARING THEREFOR, IT IS HEREBY ORDERED THAT:
25 ^ Plaintiff John Boudreau and the Proposed Class' First Amended Complaint attached as
26 Exhibit A to the Stipulation, is dcirmffd filed with the CuuiI uu i -TlZ^t^;!
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28 "ID]
IPROPOSED] ORDER RE LEAVE TO FILE FIRST AMENDED COMPLAINT
2. Defendants, and each of them, shall have thirty (30) days from the date of filing the First
2 Amended Complaint to file an answer or otherwise respond to the First Amended
3 Complaint.
4 IT IS SO ORDERED.
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Dated: H ^ ^ ^ / ^
6 the Superior Court
7 CHRISTOPHER E. KRUEGER
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[PROPOSED] ORDER F^E LEAVE TO FILE FIRST AMENDED COMPLAINT
PROOF OF SERVICE
I am employed in the County of Ventura, State of Califomia. I am over the age of eighteen
years and not a party to the within action. My business address is 5450 Telegraph Road, Suite 200,
Ventura, CA 93003.
4 On the date below, I caused to be served a trae and correct copy of the foregoing document
5 described as [PROPOSED] ORDER RE LEAVE TO FILE FIRST AMENDED COMPLAINT
on the interested parties in this action as follows:
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7 Keith A. Jacoby Attorneys for Defendants, Primeritus
Bradley E. Sch wan
8 Littler Mendelson, PC Financial Services and Chris
2049 Century Park East, 5"^ Floor McGinness
9 Los Angeles, CA 90067-3107
Tel: (310) 553-0308 / Fax: (310) 553-5583
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kjacoby@littler.com/bschwan@littler.com
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Nathaniel H. Jenkins
12 Littler Mendelson, PC
500 Capitol Mall, Suite 2000
13 Sacramento, CA 95814
14 Tel: (916) 830-7200 / Fax: (916) 561-0828
njenkins@littler.com
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16 [ X ] BY M A I L : By placing a trae copy thereof enclosed in a sealed envelope addressed to the
addressee(s) listed above. I am "readily familiar" with the firm's practice of collection and
17 processing correspondence for mailing. Under that practice, it would be deposited with the
U.S, Postal Service on that same date with postage thereon fully prepaid at Ventura,
18 Califomia, in the ordinary course of business. I am aware that on motion of the party served,
service is presumed invalid if postal cancellation date or postage meter date is more than one
19 day after date of deposit for mailing in affidavit.
20 [X] ELECTRONIC MAIL: from _@hathawaylawfirm.com and addressed to the above
listed parties.
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BY OVERNIGHT DELIVERY: By sending a trae copy thereof by ovemight delivery
22 [ ] service to the addressee(s) listed above. The envelope was deposited in or with a facility
23 regularly maintained by the ovemight carrier with delivery fees paid or provided for.
24 [X] (State) I declare under penalty of perjury under the laws of the State of Califomia that the
foregoing is trae and correct.
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Executed on March 15, 2019 at Ventura, Califomia.
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27 Edna Byerly
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[PROPOSED] ORDER RE LEAVE TO FILE FIRST AMENDED COMPLAINT