Stipulation and OrderCal. Super. - 6th Dist.March 18, 202010 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LITTLER MENDELSON, P.C. San Francisco. CA 415.433‘1940 Envelope: 5720036 KASHIF HAQUE, Bar N0. 218672 SAMUEL A. WONG, Bar N0. 2 1 7 1 04 JESSICA L. CAMPBELL, Bar No. 280626 CAROLYN M. BELL, Bar N0. 313435 cbell@aegislawfirm.com AEGIS LAW FIRM, PC 9811 Irvine Center Drive, Suite 100 Irvine, CA 926 1 8 Telephone: 949.379.6250 Fax No.2 949.379.6251 Attorneys for Plaintiff SAMUEL ABREGO, individually, and on behalf 0f all others similarly situated SOPHIA BEHNIA, Bar No. 2893 1 8 sbehnia@littler.com COLIN W. LARSON, Bar N0. 287243 clarson@littler.com LITTLER MENDELSON, P.C. 333 Bush Street, 34th Floor San Francisco, CA 94104 Telephone: 415.433.1940 Fax No.2 415.399.8490 Attorneys for Defendants STERICYCLE, INC., STERICYCLE ENVIRONMENTAL SOLUTIONS, INC., STERICYCLE SPECIALTY WASTE SOLUTIONS, INC., and SHRED-IT USA LLC SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA SAMUEL ABREGO, individually and 0n behalf of all others similarly situated, Plaintiff, V. STERICYCLE, INC., and DOES 1 through 20, inclusive, Defendants. Case No. 20CV365248 ASSIGNED FOR ALL PURPOSES TO JUDGE PATRICIA LUCAS, DEPARTMENT 3 STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE OVERLENGTH BRIEF Complaint Filed: March 18, 2020 Amended Complaint Filed: July 22, 2020 94104 STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE OVERLENGTH BRIEF xxxxxxxxxxx xxxxxxxxx Filed January 27, 2021 County of Santa Clara Superior Court of CA Clerk of the Court 20CV365248 By: rwalker 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LITTLER MENDELSON, P.C. San Francisco. CA 415.433‘1940 Plaintiff SAMUEL ABREGO (“Plaintiff”) and Defendants STERICYCLE, INC., STERICYCLE ENVIRONMENTAL SOLUTIONS, INC., STERICYCLE SPECIALTY WASTE SOLUTIONS, INC., and SHRED-IT USA LLC (collectively “Defendants”) (Plaintiff and Defendants are collectively referred t0 herein as the “Parties”), by and through their respective counsel 0f record, hereby stipulate as follows: WHEREAS, on March 18, 2020 Plaintiff filed his Class Action Complaint against Defendants in the Superior Court 0f Santa Clara County, Case No. 20CV365248; WHEREAS, Plaintiff filed his First Amended Class Action Complaint on July 22, 2020; WHEREAS, Plaintiff intends t0 seek this Court’s approval 0f the Parties’ agreement t0 settle this matter, including Plaintiff’s class claims and cause 0f action under the Private Attorneys General Act of 2004, California Labor Code sections 2698, et seq.; WHEREAS, the Parties agree that given the scope 0f this litigation and the significant number 0f complex issues, additional pages are necessary to provide the Court With a comprehensive review of the proposed settlement. NOW THEREFORE, IT IS HEREBY STIPULATED, by and between Plaintiff and Defendants, by and through their respective counsel, that the page limit for a memorandum 0f points and authorities for Plaintiff” s Motion for Preliminary Approval of Class Action Settlement and PAGA Settlement Approval may by increased t0 a total of 25 pages. IT IS SO STIPULATED. Dated: January 26, 2021 /s/ CarolynM Bell KASHIF HAQUE SAMUEL A. WONG JESSICA L. CAMPBELL CAROLYN M. BELL AEGIS LAW FIRM, PC Attorneys for Plaintiff SAMUEL ABREGO 2. 94104 STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE OVERLENGTH BRIEF 1 Dated: January 26, 2021 g g Z2 SOPHIA BEHNIA 4 COLIN W. LARSON LITTLER MENDELSON, P.C. Attorneys for Defendants 6 STERICYCLE, 1NC., STERICYCLE ENVIRONMENTAL SOLUTIONS, INC., 7 STERICYCLE SPECIALTY WASTE SOLUTIONS, INC, and SHRED-IT USA LLC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LITTLER MENDELSON, P.C. 3re . Floov San Flanciscu, CA 94104 “5"”‘94" STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE OVERLENGTH BRIEF LITTLER MENDELSON, P.C. San Francisco. CA 415.433‘1940 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 94104 [PROPOSED] ORDER Based 0n the Parties’ stipulation, and with good cause appearing, the Court orders that the page limit for a memorandum 0f points and authorities for Plaintiff” s Motion for Preliminary Approval 0f Class Action Settlement and PAGA Settlement Approval may by increased t0 a total 0f 25 pages. Dated: , 2021 THE HONORABLE PATRICIA LUCAS JUDGE OF THE SUPERIOR COURT 4846-6019-8105.1 101491.1005 4. STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE OVERLENGTH BRIEF number of complex issues" to justify a substantial increase. DENIED This stipulation gives the court no information as to what counsel consider to be a "significant xxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx January 27 \OOOQONUI-PUJNH NNNNNNNNNt-I-Ht-I-Ht-I-Ht- OONQM$UJNHOKOOOQONMJ>WNHO CERTIFICATE OF SERVICE I, the undersigned, am employed in the County 0f Orange, State 0f California. I am over the age of 18 and not a party t0 the Within action; am employed With Aegis Law Firm PC and my business address is 9811 Irvine Center Drive, Suite 100, Irvine, California 92618. On January 27, 2021, I served the foregoing document entitled: 0 STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE OVERLENGTH BRIEF 0n all the appearing and/or interested parties in this action by deliveringD the original E a true copy thereof on the party(ies) addressed below as follows: Sophia Behnia Colin Larson LITTLER MENDELSON, P.C. 333 Bush Street, 34th Floor San Francisco, CA 94 1 04 Telephone: 4 1 5.433. 1940 Fax No.2 415.399.8490 sbehnia@1ittler.com clarson littler.c0m Attorneysfor Defendants: STERICYCLE, INC., STERICYCLE ENVIRONMENTAL SOLUTIONS, INC, STERICYCLE SPECIALTY WASTE SOLUTIONS, INC, AND SHRED-IT USA LLC D (BY MAIL) I am readily familiar with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at Irvine, California in the ordinary course 0f business. I am aware that on motion of the party served, service is presumed invalid if postage cancellation date 0r postage meter date is more than one day after date of deposit for mailing this affidavit. (Cal Code Civ. Proc. § 1013(a); Fed. R. Civ. Proc. 5(a); Fed. R. Civ. Proc. 5(c).) D (BY OVERNIGHT MAIL) I am personally and readily familiar with the business practice of Aegis Law Firm PC for collection and processing correspondence for overnight delivery, and I caused such document(s) described herein t0 be deposited for delivery to a facility regularly maintained Federal Express for overnight delivery. (Cal Code Civ. Proc. § 1013(c); Fed. R. Civ. Proc. 5(c).) X (BY ELECTRONIC TRANSMISSION) I caused said document(s) to be served via electronic transmission Via the above listed email addresses on the date below. (Cal. Code Civ. Proc. § 1010.6(6); Fed. R. Civ. Proc. 5(b)(2)(E); Fed. R. Civ. Proc. 5(b)(3).) D (BY PERSONAL SERVICE) I delivered the foregoing document by hand delivery to the addressed named above. (Cal Code Civ. Proc. § 1011; Fed. R. Civ. Proc. 5(b)(2)(A)-) /// /// /// CERTIFICATE 0F SERVICE \OOOQONUI-PUJNH NNNNNNNNNt-I-Ht-I-Ht-I-Ht- OONQM$UJNHOKOOOQONMJ>WNHO I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed 0n January 27, 2021, at Irvine, California. Ma Andre rocco -2- CERTIFICATE OF SERVICE