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Mia Farber (State Bar No. 131467)
Adam Y. Sicgcl (State Bar No. 238568)
JACKSON LFWIS P.C.
725 South Figueroa Street, Suite 2500
3 Los Angeles, California 90017-5408
Tclcphone: (213) 689-0404
4 Facsimile: (213) 689-0430
F,-mail: M is. Farber~il'ucksoplcwis.cont
E-maik Adatn.S~ic0cl tl'iacl&sonlmvis.corn
6
Scott P. Jang (State Bar No. 2ti0191)
7 JACKSON LEWIS P.C.
50 California Street, 9th Floor
San Francisco, California 94111-4615
Telephone: (415) 394-9400
Facsimile: (415) 394-9401
10 E-mail:Scott.Jang&aliacksonlesvis.corn
11
Attorneys for Dcfcndant Adecco USA, Inc.
12
13 SUPERIOR COURT OF CALII ORNIA
14 COUNTY OF SAN MATEO
15
RACHEL MONIZ, on behalf of the State of Case No. 17CIV01736
16 California and aggrieved employees,
Assigned for All Purposes to
17 Plaintiff, Hott. Marie S. Weitter, Dept. 2
18 vs. AMFNDED JOINT STIPULATION AND
[PROPOSED] ORDER CONTINUING
19 ADECCO USA, INC., and DOES 1-50, APRIL 5, 2022 HLPARING ON
inclusive, PLAINTIFF'S RENEWED MOTION TO
20 APPROVE SETTLEMENT
Defendants.
21 Complaint Filed: April 18, 2017
Trial Date: None Set
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23
24
25
26
27
Ah'IEtvDED JoINT sTIPULATIQN AND [PRGPosED) QRDER coNTINUING APRIL 5, 2022 IIFARING QN
PLAINTIFF'S RENEWED MOTION TO APPROVE SETTLEMENT
I Plaintiff Rachel Moniz (" Plaintiff ') (collectively "the Parties" ), and Defendant Adecco, USA,
2 Inc. ("Adecco"), by and through their counsel of record, hereby stipulate as follows:
3 WHEREAS, on March I, 2022, the Court issued "CASE MNAGEMENT ORDER ¹ 13." In
4 that Order, the Court stated it was in receipt of the Remittitur issued from thc Court of Appeal. Also
5 in that Order, the Court sct Plaintiff's Renewed Motion to Approve Settlement Pursuant to Private
6 Attorneys General Act of 2004 for hearing on April 5, 2022, at 2:00PM;
7 WHEREAS, the Parties arc in the process of meeting and conferring over the terms of the
8 settlement to determine what changes, if any, should be made in light of the Court of Appeal's
9 decision.
10 WHEREAS, if any changes to the settlemcnt agrecmcnt are made, a new motion for approval
11 will be required anil submitted to the Court;
12 WIIEREAS, the Parties require additional time to complete their meet and confer efforts over
13 potential changes to the settlement agreement, and if any such changes are made, to draft and file
14 ncw approval papers.
15 WHEREAS, on March 10, 2022, the Parties filed a joint stipulation and proposed order
16 requesting the Court continue the April 5, 2022 approval hearing to May 24, 2022, to provide thc
17 Parties with sufficient time to complete these tasl&s;
18 WHEREAS, the Parties now have a conflict with thc requested date of May 24, 2022 and
19 thtacfore respectfully request Ihe Court continue the approval hearing to June 7, 2022 at 2:00 n.m.
20 instead of the previously requested date;
21
23
Parties'2 THEREFORE, IT
respective counsel as follows:
///
IS HEREBY STIPULATED AND AGREED, by and through the
24 ///
25 ///
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27
I
JOINT STIPULATION AND [PROPOSFD] ORDER CONTINUING APRIL 5, 2022 HEARING ON PLAINTIFF'S
RFNFWFD MOTION TO APPROVF. SETTLEMENT
The hearing on Plaintiffs Renewed Motion to Approve Settlcmcnt Pursuant to Private
Attorneys General Act of 2004 should bc continued from April 5, 2022 I.oJune 7, 2022 at 2:00 n.m.
or as soon thereafter as convenient for the Court.
Dated: March 28, 2022 SCI-INEIDER WALLACE
COTTRELL KONFCKY
WOTKYNS LLP
By: (s/ David C. Leimbach
Carolyn II. Cottrell
David C. Leimbach
10 Attorneys for Plaintiff Rachel Mon[2 and
the State of California
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Dated: March 28, 2022 JACKSON LL'WIS, P.C.
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13
14
Mia Farber
15
Adam Y. Siege[
ScoII. P. Jang
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Attorneys for Dcfcndant
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ADECCO USA, INC,
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[PROPOSEDI ORDER
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Having considered the Parties'tipulation, and for good cause shown, the Court ORDERS as
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follows;
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~ The hearing on Plaintiff's Renewed Motion to Approve Settlement Pursuant to Private
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Attorneys General Act of 2004 is continued from April 5, 2022 to June 7, 2022 at
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2;00PM.
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IT IS SO ORDERED.
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THE HONORABLE MARIE S. WEINER
JUDCxE PRESIDING
2
IMENDED JOINT STIPULATION AND [PILOPOSED] ORDER CONTINUING APRIL 5, 2022 HEARING ON
PLAINTIFF'S RENEWED MOTION TO APPROVE SETTLEMENT
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Mia Farber (State Bar No. 131467) Adam Y. Sicgcl (State Bar No. 238568) JACKSON LFWIS P.C. 725 South Figueroa Street, Suite 2500 3 Los Angeles, California 90017-5408 Tclcphone: (213) 689-0404 4 Facsimile: (213) 689-0430 F,-mail: M is. Farber~il'ucksoplcwis.cont E-maik Adatn.S~ic0cl tl'iacl&sonlmvis.corn 6 Scott P. Jang (State Bar No. 2ti0191) 7 JACKSON LEWIS P.C. 50 California Street, 9th Floor San Francisco, California 94111-4615 Telephone: (415) 394-9400 Facsimile: (415) 394-9401 10 E-mail:Scott.Jang&aliacksonlesvis.corn 11 Attorneys for Dcfcndant Adecco USA, Inc. 12 13 SUPERIOR COURT OF CALII ORNIA 14 COUNTY OF SAN MATEO 15 RACHEL MONIZ, on behalf of the State of Case No. 17CIV01736 16 California and aggrieved employees, Assigned for All Purposes to 17 Plaintiff, Hott. Marie S. Weitter, Dept. 2 18 vs. AMFNDED JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING 19 ADECCO USA, INC., and DOES 1-50, APRIL 5, 2022 HLPARING ON inclusive, PLAINTIFF'S RENEWED MOTION TO 20 APPROVE SETTLEMENT Defendants. 21 Complaint Filed: April 18, 2017 Trial Date: None Set 22 23 24 25 26 27 Ah'IEtvDED JoINT sTIPULATIQN AND [PRGPosED) QRDER coNTINUING APRIL 5, 2022 IIFARING QN PLAINTIFF'S RENEWED MOTION TO APPROVE SETTLEMENT I Plaintiff Rachel Moniz (" Plaintiff ') (collectively "the Parties" ), and Defendant Adecco, USA, 2 Inc. ("Adecco"), by and through their counsel of record, hereby stipulate as follows: 3 WHEREAS, on March I, 2022, the Court issued "CASE MNAGEMENT ORDER ¹ 13." In 4 that Order, the Court stated it was in receipt of the Remittitur issued from thc Court of Appeal. Also 5 in that Order, the Court sct Plaintiff's Renewed Motion to Approve Settlement Pursuant to Private 6 Attorneys General Act of 2004 for hearing on April 5, 2022, at 2:00PM; 7 WHEREAS, the Parties arc in the process of meeting and conferring over the terms of the 8 settlement to determine what changes, if any, should be made in light of the Court of Appeal's 9 decision. 10 WHEREAS, if any changes to the settlemcnt agrecmcnt are made, a new motion for approval 11 will be required anil submitted to the Court; 12 WIIEREAS, the Parties require additional time to complete their meet and confer efforts over 13 potential changes to the settlement agreement, and if any such changes are made, to draft and file 14 ncw approval papers. 15 WHEREAS, on March 10, 2022, the Parties filed a joint stipulation and proposed order 16 requesting the Court continue the April 5, 2022 approval hearing to May 24, 2022, to provide thc 17 Parties with sufficient time to complete these tasl&s; 18 WHEREAS, the Parties now have a conflict with thc requested date of May 24, 2022 and 19 thtacfore respectfully request Ihe Court continue the approval hearing to June 7, 2022 at 2:00 n.m. 20 instead of the previously requested date; 21 23 Parties'2 THEREFORE, IT respective counsel as follows: /// IS HEREBY STIPULATED AND AGREED, by and through the 24 /// 25 /// 26 27 I JOINT STIPULATION AND [PROPOSFD] ORDER CONTINUING APRIL 5, 2022 HEARING ON PLAINTIFF'S RFNFWFD MOTION TO APPROVF. SETTLEMENT The hearing on Plaintiffs Renewed Motion to Approve Settlcmcnt Pursuant to Private Attorneys General Act of 2004 should bc continued from April 5, 2022 I.oJune 7, 2022 at 2:00 n.m. or as soon thereafter as convenient for the Court. Dated: March 28, 2022 SCI-INEIDER WALLACE COTTRELL KONFCKY WOTKYNS LLP By: (s/ David C. Leimbach Carolyn II. Cottrell David C. Leimbach 10 Attorneys for Plaintiff Rachel Mon[2 and the State of California 11 Dated: March 28, 2022 JACKSON LL'WIS, P.C. 12 13 14 Mia Farber 15 Adam Y. Siege[ ScoII. P. Jang 16 Attorneys for Dcfcndant 17 ADECCO USA, INC, 18 [PROPOSEDI ORDER 19 Having considered the Parties'tipulation, and for good cause shown, the Court ORDERS as 20 follows; 21 ~ The hearing on Plaintiff's Renewed Motion to Approve Settlement Pursuant to Private 22 Attorneys General Act of 2004 is continued from April 5, 2022 to June 7, 2022 at 23 2;00PM. 24 25 IT IS SO ORDERED. 26 THE HONORABLE MARIE S. WEINER JUDCxE PRESIDING 2 IMENDED JOINT STIPULATION AND [PILOPOSED] ORDER CONTINUING APRIL 5, 2022 HEARING ON PLAINTIFF'S RENEWED MOTION TO APPROVE SETTLEMENT