STIPULATED MOTION TO CONSOLIDATE

RICARDO S. MARTINEZ, Chief District Judge.

COME NOW all parties hereto, by and through undersigned counsel of record, and move to consolidate three cases pursuant to the following stipulation.

STIPULATION

This case is one of three cases filed in the US District Court Western District of Washington:

These three cases are closely related. Plaintiffs in all three cases were employed by Defendant Feast Buffet, Inc. as food servers. All plaintiffs state identical causes of action, essentially asserting alleged unpaid wages. The three Complaints are virtually identical, differing only by plaintiff names and dates of employment. The dates of employment largely overlap. The same plaintiffs' counsel and defense counsel have appeared in all three actions, with the exception that there is an additional counsel for defendant Singsing Agent Services in the Xu case (Case No. C17-1583-RSM).

Consolidation of these actions would be appropriate to avoid conflict, prevent an unduly burdensome duplication of labor, discovery and expense, and conserve resources of the court and the parties. Conducting three separate cases involving the same legal theories and essentially the same evidence would not promote an efficient determination of the actions and would present a substantial potential for conflicting rulings and results.

These three actions should be consolidated through trial. Of the three current trial and case schedules, the case and trial schedule in Jinglin Chen, et. al. (Case No. C17-1584-RSM) should govern to allow completion of discovery and preparation for trial. If that case and trial schedule are not convenient for the Court, the parties respectfully request that the Court and all counsel conduct a phone conference to establish a new, streamlined trial and case schedule.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

ORDER

PURSUANT TO STIPULATION, IT IS ORDERED that cases C17-1581-RSM, C17-1583-RSM and C17-1584-RSM are consolidated through trial.