Order: Shaun Medina vs United Parcel Service, Inc. et al.

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CARNEY R. SHEGERIAN, Bar No. 150461

 

UTTILER MEHDELSON, P.C

 

e @ Anant

soe : 21082630 _ .
Filed AUG 09 2019
ROSA JUNQUEIRO, CLERK

  
  

cshegerian@shegerianlaw.com
ANTHONY NGUYEN, Bar No. 259154 By.
anguyen@shegerianlaw.com

ANAHIT TER-MAMBREYAN, Bar No. 311528
atermambreyan@shegerianlaw.com

SHEGERIAN & ASSOCIATES, INC.

225 Santa Monica Blvd., Suite 700

Santa Monica, CA 90401

Telephone: (310) 860-0770

FaxNo.: (310) 860-0771

Attorneys for Plaintiff ALAMEDA CONNTY fw DP
“ 1 Mav.3 0 2019

LISA LIN GARCIA, Bar No. 260582 e TH ~n LUURT
Igarcia@littler.com Ce mn ete tsinat
FRANCESCA M, LANPHER, Bar No. 299318 BY Deputy
flanpher@littler.com

LITTLER MENDELSON, P.C.

333 Bush Street

34th Floor

San Francisco, CA 94104

Telephone: 415.433.1940

FaxNo.: 415.399.8490

Attomeys for Defendant
UNITED PARCEL SERVICE, INC.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ALAMEDA
SHAUN MEDINA, Case No. RG19006761
Plaintiff, Assigned For All Purposes To

Judge Evelio Grillo, Dept. 15
v

   
   
  

JOINT STIPULATION AND 1
UNITED PARCEL peel - ORDER TRANSFERRING CASE TO SAN

Is JOAQUIN COUNTY

Complaint Filed: February 13, 2019

 

 

JOINT STIPULATION AND [PROPOSED] ORDER TRANSFERRING CASE TO SAN JOAQUIN COUNTY

FIRMWIDE:164570898,1 101.661.1006ce YN DH A wD

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COMES NOW, Plaintiff Shaun Medina (“Plaintiff”) and Defendant United Parcel Service,
Inc. (“Defendant” or “UPS”) collectively, the “Parties”), by and through their Tespective counsel,
hereby jointly stipulate and agree as follows:

1, The proper venue for the instant action js in San Joaquin County pursuant to
Califomia Government Code § 12965(b);

2. Pursuant to the parties’ joint agreement, the venue of this matter should be transferred
to the Superior Court of the State of California, County of San Joaquin;

3. Even with the transfer of this action to San Joaquin County Superior Court, this
action is deemed filed as of February 13, 2019, the original filing date of this action in Alameda
County Superior Court;

4. The parties agree that Plaintiff shall pay any fees that the courts charge related to
processing the transfer of venue;

5. Defendant Vivian Joshua will have thirty days to file a responsive pleading to
Plaintiff's Complaint after the date San Joaquin County Superior Court mails notice to the Parties
that the case has been received and of its new case number under Code of Civil Procedure sections
396b and 586(a)(6)(B) and Califomia Rule of Court 3.1326;

6. Defendants United Parcel Service, Inc. and Vivian Joshua will not be prejudiced from
raising any defense or objection in response to the Summons or Complaint by this change of ‘venue,
All such defenses and objections are specifically preserved; and

7. The parties agree that once the Court enters an Order approving this stipulation and
transferring this action to San Joaquin County Superior Court, Defendant’s motion for an order to

transfer venue set for hearing on June 7, 2019 at 10:00 a.m. in Department 15 will be taken off-

    

calendar and Defendant will waive attorneys’ fees and costs associated with the preparation of said

motion to transfer veriu

 

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FIRMWIDE: 164570898.) lorse1.ions ©: 2 Case No. RG19006761
JOINT STIPULATION AND [PROPOSED] ORDER TRANSFERRING CASE TO SAN JOAQUIN COUNTY“4 Dw ® ww

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UTTLER HENDELSON, F.C,

 

 

 

JOINT STIPULATION AND [PRY

Dated: May 24, 2019

Dated:

May 24, 2019

  
 
 

FIRMWIDE;164570898,1 101661,1!

CARNEY R. SHEGERIAN
ANYTHONY NGUYEN

ANAHIT TER-MAMBREYAN
SHEGERIAN & ASSOCIATES, INC.
Attomeys for Plaintiff

SHAUN MEDINA .

LISA LK

FRANCESCA M. LANPHER
LITTLER MENDELSON, P.C.
Attomeys for Defendant _
UNITED PARCEL SERVICE, INC.

: 3 Case No, RG19006761
ED] ORDER TRANSFERRING CASE TO SAN JOAQUIN COUNTY1 [PROPOSED] ORDER
2 The Court, having read and considered the parties’ Stipulation, and good cause appearing in
3 || support thereof:
4 IT IS HEREBY ORDERED that:
5 1, This matter is transferred to the Superior Court of California, County of San Joaquin;
6 2, Even with the transfer of this action to San Joaquin County Superior Court, this action is
7 deemed filed as of February 13, 2019, the original filing date of this action in Alameda
8 County Superior Court; .
9 3. Plaintiff shall pay any fees that the courts charge related to processing the transfer of
10 venue;
ll 4. Defendant Vivian Joshua will have thirty days to file a responsive pleading to Plaintiff's
12 Complaint after the date San Joaquin County Superior Court mails notice to the Parties
13 that the case has been received and of its new case number under Code of Civil Procedure
4 sections 396b and 586(a)(6)(B) and California Rule of Court 3.1326;
15 5. Defendants United Parcel Service, Inc, and Vivian Joshue will not be prejudiced from
16 raising any defense or objection in response to the Summons or Complaint by this change
17 of venue. All such defenses and objections are specifically preserved;
18 6. Defendant’s pending motion for an Order to transfer venue set for hearing on June 7,
yg 2019 at 10:00 a.m. in Department 15 is hereby taken off-calendar and Defendant waives
20 all costs and fees associated with the preparation of said motion to transfer venue;
21 7. The court clerk shall transmit a certified copy of this Order and all of the pleadings and
22 papers filed in this action to the clerk of San Joaquin County Superior Court; and
23 8.
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25 ‘ITS SO ORDERED.
26 a :
“27 | Datea__ MAY 3.0 2018 oro
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