Case: Mobley v. Workday, Inc.

CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED against Workday, Inc., (Filing Fee: $402.00, receipt number ACANDC-18008535). Filed by Derek Mobley. (Attachments: # 1 Civil Cover Sheet)(Winston, Lee) (Filed on 2/21/2023) Modified on 2/23/2023 (tn, COURT STAFF). (Entered: 02/21/2023)

1 Civil Cover Sheet

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NOTICE of Appearance by Roderick Twain Cooks (Cooks, Roderick) (Filed on 2/22/2023) (Entered: 02/22/2023)

Electronic Filing Error

~Util - Case Assigned by Intake

Electronic filing error. Incorrect Civil Cover Sheet used. Please use out most current version (October 2020) found on our website www.cand.uscourts.gov. No judge assignment will be made until the document is e-filed. Submit your document using Civil Events > Other Filings > Other Documents > Civil Cover Sheet Re: 1 Complaint filed by Derek Mobley (ark, COURT STAFF) (Filed on 2/22/2023)

Civil Cover Sheet by Derek Mobley - Corrected Civil Cover Sheet. (Cooks, Roderick) (Filed on 2/22/2023) (Entered: 02/22/2023)

Case assigned to Magistrate Judge Thomas S. Hixson. Counsel for plaintiff or the removing party is responsible for serving the Complaint or Notice of Removal, Summons and the assigned judge's standing orders and all other new case documents upon the opposing parties. For information, visit E-Filing A New Civil Case at http://cand.uscourts.gov/ecf/caseopening.Standing orders can be downloaded from the court's web page at www.cand.uscourts.gov/judges. Upon receipt, the summons will be issued and returned electronically. A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. Consent/Declination due by 3/8/2023. (ark, COURT STAFF) (Filed on 2/22/2023) (Entered: 02/22/2023)

Initial Case Management Scheduling Order with ADR Deadlines: This case may fall within the Initial Discovery Protocols for Employment Cases Alleging Adverse Action. See General Order 71. Parties and Counsel are directed to review General Order 71 to determine whether it applies to this case, and to comply with that General Order if applicable. Joint Case Management Statement due by 5/18/2023. Initial Case Management Conference set for 5/25/2023 at 10:00 AM in San Francisco, Courtroom G, 15th Floor. (tn, COURT STAFF) (Filed on 2/23/2023) (Entered: 02/23/2023)

Proposed Summons. (Winston, Lee) (Filed on 4/12/2023) (Entered: 04/12/2023)

Summons Issued as to Workday, Inc.. (slh, COURT STAFF) (Filed on 4/13/2023) (Entered: 04/13/2023)

CERTIFICATE OF SERVICE by Derek Mobley (Winston, Lee) (Filed on 4/27/2023) (Entered: 04/27/2023)

CLERK'S NOTICE Re: Consent or Declination: Plaintiffs/Defendants shall file a consent or declination to proceed before a magistrate judge by 5/11/2023. Note that any party is free to withhold consent to proceed before a magistrate judge without adverse substantive consequences. The forms are available at: http://cand.uscourts.gov/civilforms. (Party/parties were also notified via telephone or email.) (This is a text-only entry generated by the court. There is no document associated with this entry.) (tshlc1, COURT STAFF) (Filed on 5/5/2023) (Entered: 05/05/2023)

Clerk's Notice re: Consent or Declination

STIPULATION to Extend Defendant's Time to Respond to Plaintiff's Complaint filed by Workday, Inc.. (Totten, Julie) (Filed on 5/9/2023) (Entered: 05/09/2023)

STIPULATION WITH PROPOSED ORDER TO CONTINUE THE CASE MANAGEMENT CONFERENCE filed by Workday, Inc.. (Totten, Julie) (Filed on 5/11/2023) (Entered: 05/11/2023)

Clerk's Notice of Impending Reassignment - Text Only

ORDER by Magistrate Judge Thomas S. Hixson granting 11 Stipulation continuing initial case management conference. Case Management Statement due by 9/21/2023. Initial Case Management Conference set for 9/28/2023 at 10:00 AM in San Francisco, - Zoom Videoconference Only. (rmm2, COURT STAFF) (Filed on 5/11/2023) (Entered: 05/11/2023)

CONSENT/DECLINATION to Proceed Before a US Magistrate Judge by Derek Mobley.. (Winston, Lee) (Filed on 5/11/2023) (Entered: 05/11/2023)

CLERK'S NOTICE OF IMPENDING REASSIGNMENT TO A U.S. DISTRICT COURT JUDGE: The Clerk of this Court will now randomly reassign this case to a District Judge because either (1) a party has not consented to the jurisdiction of a Magistrate Judge, or (2) time is of the essence in deciding a pending judicial action for which the necessary consents to Magistrate Judge jurisdiction have not been secured. You will be informed by separate notice of the district judge to whom this case is reassigned. ALL HEARING DATES PRESENTLY SCHEDULED BEFORE THE CURRENT MAGISTRATE JUDGE ARE VACATED AND SHOULD BE RE-NOTICED FOR HEARING BEFORE THE JUDGE TO WHOM THIS CASE IS REASSIGNED. This is a text only docket entry; there is no document associated with this notice. (tshlc1, COURT STAFF) (Filed on 5/11/2023) (Entered: 05/11/2023)

ORDER REASSIGNING CASE. Case reassigned using a proportionate, random, and blind system pursuant to General Order No. 44 to Judge Yvonne Gonzalez Rogers for all further proceedings. Magistrate Judge Thomas S. Hixson no longer assigned to case, Notice: The assigned judge participates in the Cameras in the Courtroom Pilot Project. See General Order No. 65 and http://cand.uscourts.gov/cameras.. Signed by Clerk on 5/12/2023. (Attachments: # 1 Notice of Eligibility for Video Recording)(ark, COURT STAFF) (Filed on 5/12/2023) (Entered: 05/12/2023)

CLERK'S NOTICE. (This is a text-only entry generated by the court. There is no document associated with this entry.). Case Management Statement due by 9/25/2023. Initial Case Management Conference set for 10/2/2023 02:00 PM in Oakland, - Videoconference Only. This proceeding will be held via a Zoom webinar. Webinar Access: All counsel, members of the public, and media may access the webinar information at https://www.cand.uscourts.gov/ygr Court Appearances: Advanced notice is required of counsel or parties who wish to be identified by the court as making an appearance or will be participating in the argument at the hearing. A list of names and emails must be sent to the CRD at YGRCRD@cand.uscourts.gov no later than September 29, 2023 at 12:00 PM PST. General Order 58. Persons granted access to court proceedings held by telephone or videoconference are reminded that photographing, recording, and rebroadcasting of court proceedings, including screenshots or other visual copying of a hearing, is absolutely prohibited. Zoom Guidance and Setup: https://www.cand.uscourts.gov/zoom/. (eac, COURT STAFF) (Filed on 5/15/2023) (Entered: 05/15/2023)

Clerk's Notice AND ~Util - Teleconference Zoom

MOTION to Dismiss and Memorandum of Points and Authorities in Support filed by Workday, Inc.. Motion Hearing set for 9/12/2023 02:00 PM in Oakland, Courtroom 1, 4th Floor before Judge Yvonne Gonzalez Rogers. Responses due by 7/31/2023. Replies due by 8/7/2023. (Attachments: # 1 Defendant Workday, Inc.s Request for Judicial Notice in Support of Its Motion to Dismiss Plaintiffs Complaint, # 2 [Proposed] Order Granting Defendant Workday Inc.s Motion to Dismiss)(Totten, Julie) (Filed on 7/17/2023) (Entered: 07/17/2023)

1 Defendant Workday, Inc.s Request for Judicial Notice in Support of Its Motion t

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2 [Proposed] Order Granting Defendant Workday Inc.s Motion to Dismiss

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CORPORATE DISCLOSURE STATEMENT AND CERTIFICATION OF CONFLICTS AND INTERESTED ENTITIES OR PERSONS filed by Workday, Inc. (Totten, Julie) (Filed on 7/17/2023) (Entered: 07/17/2023)

First MOTION for Extension of Time to File Response/Reply as to 17 MOTION to Dismiss and Memorandum of Points and Authorities in Support filed by Derek Mobley. (Attachments: # 1 Declaration Declaration of Roderick T. Cooks, # 2 Proposed Order)(Cooks, Roderick) (Filed on 7/25/2023) (Entered: 07/25/2023)

ORDER TO SHOW CAUSE Plaintiff's Show Cause Response due by 7/31/2023. Signed by Judge Yvonne Gonzalez Rogers on 7/25/2023. (eac, COURT STAFF) (Filed on 7/25/2023) (Entered: 07/25/2023)

RESPONSE TO ORDER TO SHOW CAUSE by Derek Mobley . (Cooks, Roderick) (Filed on 7/31/2023) (Entered: 07/31/2023)

MISCELLANEOUS ORDER. Plaintiff's Application with Local Counsel due by 8/16/2023. Signed by Judge Yvonne Gonzalez Rogers on 8/1/2023. (eac, COURT STAFF) (Filed on 8/1/2023) (Entered: 08/01/2023)

MOTION for Extension of Time to File Motion for Additional Time to Secure Local Counsel filed by Derek Mobley. (Cooks, Roderick) (Filed on 8/14/2023) (Entered: 08/14/2023)

Miscellaneous Order by Judge Yvonne Gonzalez Rogers Granting 23 Motion for Extension of Time to File. Plaintiff's counsel to secure local counsel by 8/30/2023. (eac, COURT STAFF) (Filed on 8/17/2023) (Entered: 08/17/2023)

MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 317, receipt number ACANDC-18600696.) filed by Derek Mobley. (Attachments: # 1 Exhibit Certificate of Good Standing)(Winston, Lee) (Filed on 8/30/2023) (Entered: 08/30/2023)

MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 317, receipt number ACANDC-18602131.) filed by Derek Mobley. (Attachments: # 1 Exhibit Certificate of Good Standing)(Cooks, Roderick) (Filed on 8/30/2023) (Entered: 08/30/2023)

Order by Judge Yvonne Gonzalez Rogers Granting 25 Application for Admission of Attorney Pro Hac Vice. (eac, COURT STAFF) (Filed on 8/31/2023) (Entered: 08/31/2023)

Order by Judge Yvonne Gonzalez Rogers Granting 26 Application for Admission of Attorney Pro Hac Vice. (eac, COURT STAFF) (Filed on 8/31/2023) (Entered: 08/31/2023)

CLERK'S NOTICE Re: 17 Motion to Dismiss and Memorandum of Points and Authorities in Support. You are hereby notified that the motion to dismiss hearing previously set for 9/12/2023 is reset to 10/10/2023 at 2:00 PM in Oakland, Courtroom 1, 4th Floor before Judge Yvonne Gonzalez Rogers. (This is a text-only entry generated by the court. There is no document associated with this entry.) (eac, COURT STAFF) (Filed on 9/1/2023) (Entered: 09/02/2023)

Clerk's Notice

ADR Clerks Notice re: Non-Compliance with Court Order. The parties have failed to file an ADR Certification as required by the Initial Case Management Scheduling Order. Counsel shall comply promptly with the requirements of ADR L.R. 3-5(b) and shall file the ADR Certification. (This is a text-only entry generated by the court. There is no document associated with this entry.)(cmf, COURT STAFF) (Filed on 9/12/2023) (Entered: 09/12/2023)

ADR Clerks Notice re: Non-Compliance after 5/1/2018

STIPULATION WITH PROPOSED ORDER to Continue Case Management Conference and Related Dates filed by Workday, Inc.. (Totten, Julie) (Filed on 9/13/2023) (Entered: 09/13/2023)

Document Missing Cover Page. Please refer to Corrected Filing 33 OPPOSITION/RESPONSE (re 17 MOTION to Dismiss and Memorandum of Points and Authorities in Support ) filed byDerek Mobley. (Attachments: # 1 Exhibit Request for Judicial Notice)(Cooks, Roderick) (Filed on 9/13/2023) Modified on 9/14/2023 (mbc, COURT STAFF). (Entered: 09/13/2023)

1 Exhibit Request for Judicial Notice

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OPPOSITION/RESPONSE (re 17 MOTION to Dismiss and Memorandum of Points and Authorities in Support ) Corrected Copy with Cover Page filed byDerek Mobley. (Attachments: # 1 Exhibit Request for Judicial Notice)(Cooks, Roderick) (Filed on 9/13/2023) (Entered: 09/13/2023)

Order by Judge Yvonne Gonzalez Rogers Granting 31 Stipulation to Continue Case Management Conference and Related Dates. Case Management Conference previously set for 10/2/2023 is vacated and will be reset by the Court. (eac, COURT STAFF) (Filed on 9/14/2023) (Entered: 09/14/2023)

REPLY (re 17 MOTION to Dismiss and Memorandum of Points and Authorities in Support ) in Support of its Motion to Dismiss filed byWorkday, Inc.. (Totten, Julie) (Filed on 9/25/2023) (Entered: 09/25/2023)

OPPOSITION/RESPONSE (re 17 MOTION to Dismiss and Memorandum of Points and Authorities in Support ) Opposition to Plaintiff's Request for Judicial Notice filed byWorkday, Inc.. (Totten, Julie) (Filed on 9/25/2023) (Entered: 09/25/2023)

CLERK'S NOTICE. You are hereby notified that the Motion to Dismiss Hearing previously set for 10/10/2023 is vacated, it will be reset by the Court if necessary. (This is a text-only entry generated by the court. There is no document associated with this entry.) (eac, COURT STAFF) (Filed on 9/27/2023) (Entered: 09/27/2023)

Clerk's Notice

ORDER REASSIGNING CASE.IT IS ORDERED that this case is reassigned to the Honorable Rita F. Lin in the San Francisco Division for all further proceedings.1. All future filings shall bear the initials RFL immediately after the case number.2. All case management conference dates are vacated and will be reset by the Court.3. All hearing dates presently scheduled are VACATED. However, existing briefing schedules for motions remain unchanged. All pending motions (regardless of whether they are presently scheduled for hearing) must be RENOTICED for hearing before Judge Lin by the moving party for a date consistent with the Court’s law and motion calendar, but the renoticing of the hearing does not affect the prior briefing schedule.4. Deadlines for ADR compliance and discovery cutoffs remain unchanged.5. All pretrial conference and trial dates currently set for after March 4, 2024, and all other deadlines associated with the case, will remain in place unless otherwise ordered.6. All pretrial conference and trial dates scheduled on or before March 4, 2024, are vacated. Other pretrial deadlines (eg., motions in limine, pretrial statements, proposed joint trial exhibits, etc.) will remain in place. The Court will notify the parties when a status conference will be held to schedule a new pretrial conference and trial dates for affected cases.7. Matters currently referred to a Magistrate Judge will remain before that Magistrate Judge absent further notice.8. Each party is expected to review and become familiar with all applicable standing orders and scheduling notes.9. On or before December 11, 2023, the parties shall file a Joint Case Management Statement (separate statements are appropriate if either party is proceeding without counsel). The statement should not exceed ten pages in length and should address the following items in the following order: a. Date Filed: The date the case was filed; b. Parties: A list or description of each party; c. Claims: A summary of all claims, counter-claims, cross-claims, or third party claims; d. Facts: A brief chronology of the facts and a statement of the principal factual issues in dispute; e. Legal Issues: A brief statement, without extended legal argument, of the disputed points of law, including reference to specific statutes and decisions; f. Relief: A description of the relief sought and the damages claimed with an explanation as to how damages have been (or will be) computed; g. Discovery: The status of discovery, including any significant discovery management issues, as well as any limits or cutoff dates; h. Related Cases: The status, case name, and case number of any related cases or proceedings pending before another judge of this court, or before another court or administrative body; i. Procedural History: A procedural history of the case, including any previous motions that were decided or submitted, any ADR proceedings or settlement conferences that have been scheduled or concluded, any appellate proceedings that are pending or concluded, and any previous referral to a magistrate judge; j. Deadlines: A description of any other deadlines in place before reassignment, including those for ADR, dispositive motions, pretrial conferences, and trials; k. Any modification of deadlines: Any requested modification of these dates, and the reasons for the request; l. Consent to Magistrate: Whether the parties will consent to a magistrate judge for trial; and m. Emergency: Whether there exists an immediate need for a case management conference to be scheduled in the action, and why the parties believe such a need exists.10. The Joint Case Management Statement will not constitute a motion to extend or modify dates. If emergency relief is needed to modify a deadline, and the deadline is not of the type that can be modified via stipulation of the parties without a court order, the requesting party or parties shall additionally file a motion or stipulation for such relief in compliance with Local Rule 6.11. The assigned judge participates in the Cameras in the Courtroom Pilot Project. Hearings and trials in any civil case assigned to a judge participating in the Pilot Project are eligible for video recording, upon request and with the consent of the parties and the presiding judge. Please see the Northern Districts webpage about participation in the Pilot Project and General Order 65 for more information. IT IS SO ORDERED.Dated: 11/27/2023FOR THE EXECUTIVE COMMITTEEMark B. Busby, Clerk of Court (kab-adi, COURT STAFF) (Filed on 11/27/2023) (Entered: 11/27/2023)

Clerks Notice ADI

Case Assigned/Reassigned

Case Reassigned to Judge Rita F. Lin. Judge Yvonne Gonzalez Rogers no longer assigned to the case. Notice: The assigned judge participates in the Cameras in the Courtroom Pilot Project. See General Order No. 65 and http://cand.uscourts.gov/cameras. (jlm, COURT STAFF) (Filed on 11/28/2023)

NOTICE by Workday, Inc. re 17 MOTION to Dismiss and Memorandum of Points and Authorities in Support Amended Notice of Hearing on Motion to Dismiss (Totten, Julie) (Filed on 12/5/2023) (Entered: 12/05/2023)

Set Motion and Deadlines/Hearings

Set/Reset Deadlines as to 17 MOTION to Dismiss and Memorandum of Points and Authorities in Support. Motion Hearing reset for 1/9/2024 10:00 AM in San Francisco, Courtroom 15, 18th Floor before Judge Rita F. Lin. (mkl, COURT STAFF) (Filed on 12/6/2023)

JOINT CASE MANAGEMENT STATEMENT filed by Workday, Inc.. (Grundy, Kayla) (Filed on 12/8/2023) (Entered: 12/08/2023)

NOTICE OF QUESTIONS FOR HEARING. Signed by Judge Rita F. Lin on 1/3/2024. (mkl, COURT STAFF) (Filed on 1/3/2024) (Entered: 01/03/2024)

Minute Entry for proceedings held before Judge Rita F. Lin: Motion Hearing held on 1/9/2024 re 17 MOTION to Dismiss and Memorandum of Points and Authorities in Support filed by Workday, Inc. Counsel should provide a list of citations referenced at the hearing to the clerk by email (RFLCRD@cand.uscourts.gov) no later than Friday 1/12/2024. Argument heard. The Court takes the matter under submission and will issue a written order. Total Time in Court: 50 minutes. Court Reporter: Jennifer Coulthard. Attorneys for Plaintiff: Roderick Cooks and Lee Winston. Defendant Attorney: Erin Connell, Julie Totten, and Kayla Grundy. (This is a text-only entry generated by the court. There is no document associated with this entry.) (mkl, COURT STAFF) (Date Filed: 1/9/2024) Modified on 1/9/2024 (mkl, COURT STAFF). (Entered: 01/09/2024)

Motion Hearing

TRANSCRIPT ORDER for proceedings held on January 9, 2024 before Judge Rita F. Lin by Workday, Inc., for Court Reporter Jennifer Coulthard. (Grundy, Kayla) (Filed on 1/9/2024) (Entered: 01/09/2024)

TRANSCRIPT ORDER for proceedings held on 01/09/2023 before Judge Rita F. Lin by Derek Mobley, for Court Reporter Jennifer Coulthard. (Cooks, Roderick) (Filed on 1/11/2024) (Entered: 01/11/2024)

ORDER by Judge Rita F. Lin granting 17 Motion to Dismiss with Leave to Amend. Amended Complaint due by 2/20/2024. (mkl, COURT STAFF) (Filed on 1/19/2024) (Entered: 01/19/2024)

Transcript of Proceedings held on 1/9/2024, before Judge Lin. Court Reporter/Transcriber Jennifer Coulthard, telephone number (530)537-9312. Per General Order No. 59 and Judicial Conference policy, this transcript may be viewed only at the Clerk's Office public terminal or may be purchased through the Court Reporter/Transcriber until the deadline for the Release of Transcript Restriction. After that date it may be obtained through PACER. Any Notice of Intent to Request Redaction, if required, is due no later than 5 business days from date of this filing. (Re 43 Transcript Order, 44 Transcript Order ) Redaction Request due 2/20/2024. Redacted Transcript Deadline set for 2/28/2024. Release of Transcript Restriction set for 4/29/2024. (Related documents(s) 43, 44 ) (Coulthard, Jennifer) (Filed on 1/28/2024) (Entered: 01/28/2024)

AMENDED COMPLAINT against Workday, Inc.. Filed by Derek Mobley. (Cooks, Roderick) (Filed on 2/20/2024) (Entered: 02/20/2024)

STIPULATION WITH PROPOSED ORDER to Extend Time to Respond to First Amended Class Action Complaint filed by Workday, Inc.. (Totten, Julie) (Filed on 2/26/2024) (Entered: 02/26/2024)

ORDER by Judge Rita F. Lin granting 48 Stipulation to Extend Time to Respond to First Amended Class Action Complaint. (mkl, COURT STAFF) (Filed on 2/27/2024) (Entered: 02/27/2024)