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Samuel Brandon Kress, et al v. Pricewaterhousecoopers Llp

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


February 15, 2011

SAMUEL BRANDON KRESS, ET AL.,
PLAINTIFFS,
v.
PRICEWATERHOUSECOOPERS LLP,
DEFENDANTS.

JOINT STIPULATION AND ORDER FOR PLAINTIFFS TO FILE A SECOND AMENDED CONSOLIDATED

CLASS/COLLECTIVE ACTION

COMPLAINT TO ADD ADDITIONAL NAMED PLAINTIFFS AND PROPOSED CLASS REPRESENTATIVES

Plaintiffs Samuel Brandon Kress, Lac Anh Le, Jason Patterson, Lauren San Mateo, James Stekelberg, Jeffrey LaBerge, Willow Markham, Dana Blindbury, Jesse Kenny, Kelly C. Jones, and Antoine Powell (collectively, "Plaintiffs") and Defendant PricewaterhouseCoopers LLP ("Defendant" or "PwC") (together, "the parties"), by and through their respective counsel, hereby stipulate to the filing of a Second Amended Consolidated Class/Collective Action Complaint in this matter to add Albert Liu, Daniel Gonzalez, and David Beadles as named plaintiffs and proposed class representatives as to a proposed class of Associates and/or Senior Associates in PwC's Tax line of service in California.

WHEREAS, Plaintiffs filed the operative Amended Consolidated Class/Collective Action Complaint in this action on December 24, 2008 (Docket Entry 45).

WHEREAS, as previously set forth in the parties' Stipulation and [Proposed] Order Re Class Certification Motions and Trial Schedule approved by this Court on January 20, 2011 (Docket Entry 196), Plaintiffs desire to add Albert Liu, Daniel Gonzalez, and David Beadles, who worked in Defendant's Tax line of service in California, as named plaintiffs and proposed class representatives and, accordingly, seek to file a Second Amended Consolidated Class/Collective Action Complaint for that and no other purpose.

WHEREAS, Plaintiffs represent that they do not seek to amend the operative complaint to add Albert Liu, Daniel Gonzalez, and David Beadles as named plaintiffs and proposed class representatives for the purpose of delay, but rather to promote efficiency and to expeditiously advance the interests of the putative class of Associates and Senior Associates who worked in Defendant's tax line of service in California.

WHEREAS, Plaintiffs represent that the proposed amendment will have no effect on any existing case management deadlines, given that the parties are presently engaged in discovery regarding Plaintiffs' proposed Rule 23 classes consisting of Associates and Senior Associates in Defendant's Tax line of service in California ("Rule 23 Tax Class") and Senior Associates in Defendant's Assurance line of service in California ("Rule 23 Assurance Class"); the deadline for Plaintiffs to file their motion for certification of a Rule 23 Tax Class is June 13, 2011; and the deadline for Plaintiffs to file their motion for certification of a Rule 23 Assurance Class is 45 days after a decision is rendered by the Ninth Circuit in the matter of Campbell v. PricewaterhouseCoopers, LLP, Case No. 06-cv-2376-LKK-GGH ("Campbell"), but in any event no earlier than August 1, 2011.

WHEREAS, the parties agree that Defendant is entitled to conduct discovery with respect to Mr. Liu, Mr. Gonzalez, and Mr. Beadles, and that they will attempt in good faith to complete that discovery in a manner that does not affect any existing case management deadlines in this case.

WHEREAS, the parties have met and conferred regarding the filing of Plaintiffs' Second Amended Consolidated Class/Collective Complaint.

WHEREAS, the parties agree that any proposed classes that Plaintiffs Liu, Gonzalez, or Beadles purport to represent shall be limited to proposed classes of California employees in PwC's Tax line of service, pursuant to Federal Rule of Civil Procedure 23.

NOW, THEREFORE, IT IS STIPULATED AND AGREED by and between Plaintiffs and Defendant, by and through their respective undersigned counsel, for the filing of a Second Amended Consolidated Class/Collective Action Complaint in the form and substance attached hereto as Exhibit A to add Albert Liu, Daniel Gonzalez, and David Beadles as additional named plaintiffs and proposed class representatives. Defendant's Answer to Plaintiffs' Consolidated Class/Collective Action Complaint in this action, filed on October 6, 2008 (Docket Number 32) shall serve as Defendant's Answer to Plaintiffs' Second Amended Consolidated Class/Collective Action Complaint.

February 9, 2011

MARKUN ZUSMAN & COMPTON LLP ORRICK, HERRINGTON & SUTCLIFFE LLP By: William A. Baird - and - By: Julie A. Totten BARROWAY TOPAZ KESSLER KESSLER MELTZER & CHECK, LLP Norman C. Hile (SBN 57299) Julie A. Totten (SBN 166470) WYNNE LAW FIRM David A. Prahl (SBN 233583) Edward J. Wynne Andrea L. Brown (SBN 237629) - and -LAW OFFICE OF STEVEN ELSTER Lynne C. Hermle (SBN 99779) Steven Elster Counsel for Defendant Counsel for Plaintiffs

SO ORDERED:

20110215

© 1992-2011 VersusLaw Inc.



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