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STIPULATION TO TRANSFER CASE / CASE NO. 13:14-CV-03256-VC

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NICHOLS KASTER, PLLP

Matthew C. Helland (SBN 250451)

helland@nka.com

One Embarcadero Center, Suite 720

San Francisco, California 94111

Telephone: (415) 277-7235

Facsimile: (415) 277-7238

Attorneys for Plaintiffs LASANDRA

HILLSON, STEVEN BOHLER, and

ASHLEY SCHMIDT, individually and as

representatives of a class

NICHOLS KASTER, PLLP

Daniel C. Bryden (pro hac vice)

dbryden@nka.com

Megan D. Yelle (pro hac vice)

myelle@nka.com

4600 IDS Center

80 South 8th Street

Minneapolis, MN 55402

Telephone: (612) 256-3200

Facsimile: (612) 338-4878

SEYFARTH SHAW LLP

Gerald L. Maatman, Jr. (pro hac vice)

gmaatman@seyfarth.com

Pamela Q. Devata (pro hac vice)

pdevata@seyfarth.com

131 South Dearborn Street, Suite 2400

Chicago, Illinois 60603

Telephone: (312) 460-5882

Facsimile: (312) 460-7882

Attorneys for Defendant

KELLY SERVICES, INC.

SEYFARTH SHAW LLP

Laura J. Maechtlen (SBN 224923)

lmaechtlen@seyfarth.com

560 Mission Street, 31st Floor

San Francisco, California 94105

Telephone: (415) 397-2823

Facsimile: (415) 397-8549

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

LASANDRA HILLSON, STEVEN

BOHLER, and ASHLEY SCHMIDT,

individually and as representatives of the

class,

Plaintiffs,

v.

KELLY SERVICES, INC.,

Defendant.

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Case No. 3:14-cv-03256-VC

STIPULATION AND [PROPOSED]

ORDER TO TRANSFER VENUE TO THE

EASTERN DISTRICT OF MICHIGAN

Judge: Honorable Vince Chhabria

Dept.: 4

First Amended Complaint Filed:

August 19, 2014

2:15-cv-10803-LJM-APP Doc # 3 Filed 03/05/15 Pg 1 of 4 Pg ID 39
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STIPULATION TO TRANSFER CASE / CASE NO. 13:14-CV-03256-VC

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STIPULATION

Plaintiffs LaSandra Hillson, Steven Bohler, and Ashley Schmidt, and Defendant Kelly

Services, Inc., by their respective attorneys and pursuant to 28 U.S.C. § 1404(a) and L.R. 3-2(h),

hereby enter the following stipulation, which requests transfer of this action to the United States

District Court for the Eastern District of Michigan, Detroit Division.

Plaintiffs filed this action on July 18, 2014 in the Northern District of California. The

Parties now jointly stipulate as follows: (1) this case could have been brought in Eastern District

of Michigan, Detroit Division; (2) venue is proper in the Eastern District of Michigan, Detroit

Division; and (3) without Plaintiffs conceding the validity of any such clause or documents,

Defendant has produced documents including a forum selection clause that sets forth that

disputes between the parties must be litigated in the State of Michigan. Thus, the parties

stipulate that, under 28 U.S.C. § 1404(a) and L.R. 3-2(h), the Eastern District of Michigan,

Detroit Division, is the appropriate venue for this action, and that this action should be

transferred to that venue for the convenience of parties and witnesses and in the interests of

justice. The Case Management Conference currently scheduled for March 10, 2015 should be

taken off-calendar.

Accordingly, the parties have submitted contemporaneously herewith a [Proposed] Order

transferring this action to the Eastern District of Michigan, Detroit Division.

Stipulated and respectfully submitted,

DATED: March 2, 2015

By:

NICHOLS KASTER, LLP

/s/ Megan D. Yelle

Megan D. Yelle (pro hac vice)

Attorneys for Plaintiffs

LASANDRA HILLSON, STEVEN BOHLER,

and ASHLEY SCHMIDT, individually and as

representatives of a class

2:15-cv-10803-LJM-APP Doc # 3 Filed 03/05/15 Pg 2 of 4 Pg ID 40
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STIPULATION TO TRANSFER CASE / CASE NO. 13:14-CV-03256-VC

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DATED: March 2, 2015

By:

SEYFARTH SHAW LLP

/s/ Laura J. Maechtlen

Gerald L. Maatman, Jr. (pro hac vice)

Pamela Q. Devata (pro hac vice)

Laura J. Maechtlen

Attorneys for Defendant

KELLY SERVICES, INC.

2:15-cv-10803-LJM-APP Doc # 3 Filed 03/05/15 Pg 3 of 4 Pg ID 41
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STIPULATION TO TRANSFER CASE / CASE NO. 13:14-CV-03256-VC

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[PROPOSED] ORDER TO TRANSFER VENUE

TO THE EASTERN DISTRICT OF MICHIGAN

Currently before this Court is the parties’ Stipulation to Transfer Venue to the Eastern

District of Michigan, Detroit Division, pursuant to 28 U.S.C. § 1404(a) and L.R. 3-2(h). The

parties further stipulate that, under 28 U.S.C. § 1404(a) and L.R. 3-2(h), the Eastern District of

Michigan, Detroit Division, is the appropriate venue for this action, and that this action should be

transferred to that venue for the convenience of parties and witnesses and in the interests of

justice.

Based on this stipulation, this Court finds that, pursuant to 28 U.S.C. § 1404(a) and L.R.

3-2(h), this action should be transferred to the United States District Court for the Eastern

District of Michigan, Detroit Division. Accordingly, this Court ORDERS that this case be

transferred to the United States District Court for the Eastern District of Michigan, Detroit

Division. The Case Management Conference currently scheduled for March 10, 2015, is taken

off-calendar.

IT IS SO ORDERED.

Dated: ______________________________________

Hon. Vince Chhabria

United States District Court Judge

March 3, 2015

2:15-cv-10803-LJM-APP Doc # 3 Filed 03/05/15 Pg 4 of 4 Pg ID 42