Pacleb v. Salt & Straw, LLC et al

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO FILE OPPOSITION TO
PLAINTIFF’S MOTION TO REMAND
Mark D. Kemple (SBN 145219)
kemplem@gtlaw.com
Jonathan A. Schaub (SBN 298892)
Jonathan.Schaub@gtlaw.com
Elizabeth A. Morehouse (SBN 357011)
Libby.Morehouse@gtlaw.com
GREENBERG TRAURIG, LLP
1840 Century Park East, Suite 1900
Los Angeles, California 90067-2121
Telephone: 310.586.7700
Attorneys for Defendants Salt & Straw, LLC; Salt &
Straw Inc., and Salt & Straw Holdings, LLC
Ryan T. Chuman (State Bar No. 300695)
rchuman@blackstonepc.com
Arnel O. Tan (State Bar No. 272428)
atan@blackstonepc.com
BLACKSTONE LAW, APC
8383 Wilshire Boulevard, Suite 745
Beverly Hills, California 90211
Telephone: (310) 622-4278 / Facsimile: (855) 786-6356
Attorneys for Plaintiff
Matthew Pacleb
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
MATTHEW PACLEB, individually, and
on behalf of other similarly situated
employees,
Plaintiff,
v.
SALT & STRAW, LLC; SALT &
STRAW INC.; SALT & STRAW
HOLDINGS, LLC; and DOES 1 through
25, inclusive,
Defendants.
Case No. 4:26-cv-10418-HSG
JOINT STIPULATION TO EXTEND
DEFENDANTS’ TIME TO FILE
OPPOSITION TO PLAINTIFF’S
MOTION TO REMAND [DKT. 20];
ORDER
Removal Filed: September 16, 2026
State Action Filed: February 17, 2026
Case 4:26-cv-10418-HSG Document 27 Filed 10/13/26 Page 1 of 7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
JOINT STIPULATION TO EXPAND DEFENDANTS’ TIME TO FILE OPPOSITION TO
PLAINTIFF’S MOTION TO REMAND
JOINT STIPULATION
Pursuant to Civil L.R. 6-2, Plaintiff Matthew Pacleb (“Plaintiff”) and Defendants Salt
& Straw, LLC, Salt & Straw Inc., and Salt & Straw Holdings, LLC (“Defendants”)
(together, the “Parties”), by and through their respective counsel of record, stipulate to
extend Defendants’ deadline to oppose Plaintiff’s Motion to Remand [Dkt. 20] by one week
as follows:
WHEREAS, on September 14, 2026, Defendants removed this action to this Court
from the Superior Court of California for the County of San Mateo [Dkt. 1, 3];
WHEREAS, 	on September 21, 2026, Defendants filed a Motion to Compel
Arbitration [Dkt. 8] and Motion to Dismiss [Dkt. 9];
WHEREAS, on October 5, 2026, Plaintiff filed Oppositions to both the Motion to
Compel Arbitration [Dkt. 23] and Motion to Dismiss [Dkt. 22];
WHEREAS, also on October 5, 2026, Plaintiff filed a Motion to Remand this matter
[Dkt. 20], despite having until at least October 14, 2026 to do so;
WHEREAS, 	Defendants’ 	Reply 	briefs 	supporting 	their 	Motion 	to 	Compel
Arbitration and Motion to Dismiss are due on or before October 13, 2026;
WHEREAS, Defendants’ current deadline to file their Opposition to Plaintiff’s
Motion to Remand is October 19, 2026;
WHEREAS, on October 6, 2026, the Court set the hearings for Defendants’ Motion
to Compel Arbitration and Motion to Dismiss and Plaintiff’s Motion to Remand for the
same date, January 7, 2027 [Dkt. 25];
WHEREAS, between October 6, 2026 and October 8, 2026, the Parties met and
conferred regarding a potential extension of the deadline for Defendants to oppose
Plaintiff’s Motion to Remand Defendants’ Opposition in light of Defendants’ October 13,
2026 Reply filing deadlines and the travel schedule of Defendants’ lead counsel; and
stipulate to extend Defendants’ time to file the Opposition by one week, up to and including
October 26, 2026; and
Case 4:26-cv-10418-HSG Document 27 Filed 10/13/26 Page 2 of 7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
JOINT STIPULATION TO EXPAND DEFENDANTS’ TIME TO FILE OPPOSITION TO
PLAINTIFF’S MOTION TO REMAND
WHEREAS, in light of the fact that the hearing date on Plaintiff’s Motion to Remand
is not set until January 7, 2027, the Parties agree that there would be no prejudice to either
party or the Court in extending Defendants’ opposition deadline by one week;
NOW, THEREFORE, it is hereby stipulated and agreed by and between the Parties,
subject to the Court’s approval, that:
1. 	Defendants’ time to file and serve their Opposition should be extended by one
week up to and including October 26, 2026; and
2. 	Plaintiff’s Reply deadline should be extended to November 2, 2026.
IT IS SO STIPULATED
Respectfully submitted,
Dated: October 9, 2026 	GREENBERG TRAURIG, LLP
By 	/s/ Mark D. Kemple
Mark D. Kemple
Attorneys for Defendants
Salt & Straw, LLC; Salt & Straw Inc.,
and Salt & Straw Holdings, LLC
Dated: October 9, 2026 	BLACKSTONE LAW, APC
By 	/s/Ryan Chuman
Ryan T. Chuman
Arnel O. Tan
Attorneys for Plaintiff
Matthew Pacleb
Case 4:26-cv-10418-HSG Document 27 Filed 10/13/26 Page 3 of 7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4
JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO FILE OPPOSITION TO
PLAINTIFF’S MOTION TO REMAND
ATTESTATION
Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this
document has been obtained from each of the other signatories above.
Dated: October 9, 2026 	GREENBERG TRAURIG, LLP
By 	/s/ Mark D. Kemple
Mark D. Kemple
Attorneys for Defendants
Salt & Straw, LLC; Salt & Straw Inc.,
and Salt & Straw Holdings, LLC
Case 4:26-cv-10418-HSG Document 27 Filed 10/13/26 Page 4 of 7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
5
JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO FILE OPPOSITION TO
PLAINTIFF’S MOTION TO REMAND
DECLARATION OF MARK KEMPLE
I, Mark Kemple, declare as follows:
1. 	I am an attorney at law duly licensed to practice law in the State of California.
I am a shareholder at the law firm of Greenberg Traurig, LLP, and counsel of record for
Defendants Salt & Straw, LLC, Salt & Straw Inc., and Salt & Straw Holdings, LLC
(together, “Defendants”) in this action. Except as otherwise noted, I make this declaration
based on my personal knowledge and, if called by a court of law, could and would
completely testify to the facts set forth herein.
2. 	On September 14, 2026, Defendants removed this action from the Superior
Court of California for the County of San Mateo. [Dkt. 1, 3.]
3. 	On September 21, 2026, Defendants filed the Motion to Compel Arbitration
[Dkt. 8] and Motion to Dismiss [Dkt. 9]. On October 5, 2026, Plaintiff filed his Opposition
to Defendants’ Motion to Compel Arbitration [Dkt. 23] and Opposition to Defendants’
Motion to Dismiss [Dkt. 22]. Defendants’ Reply briefs in support of their Motion to Compel
Arbitration and Motion to Dismiss are due on or before October 13, 2026.
4. 	Also on October 5, 2026, Plaintiff filed his Motion to Remand [Dkt. 20], despite
having until at least October 14, 2026 to do so.
5. 	I will be out of town and on vacation for five of the fourteen days between
October 5th (date Plaintiff filed the Motion to Remand) and October 19th (Defendants’
current deadline to oppose), and will also be focused during that time on Defendants’
Replies in support of the Motion to Compel Arbitration and Motion to Dismiss. As
Defendants’ lead counsel, my involvement and availability is crucial to representation of
Defendants in this matter.
6. 	On October 6, 2026, immediately after receiving Plaintiff’s Motion to Remand,
I emailed Plaintiff’s counsel explaining the timing consideration above, including my travel,
and requested that Plaintiff stipulate to a one-week extension of Defendants’ deadline to file
an opposition to the Motion to Remand. After meeting and conferring, on October 8, 2026,
the parties reached agreement to stipulate to extend Defendants’ opposition date one week,
Case 4:26-cv-10418-HSG Document 27 Filed 10/13/26 Page 5 of 7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
6
JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO FILE OPPOSITION TO
PLAINTIFF’S MOTION TO REMAND
up to and including October 26, 2026.
7. 	The Parties previously stipulated to have Plaintiff’s Motion to Remand heard
before Defendants’ Motion to Compel Arbitration and Motion to Dismiss. The Court so
ordered, rescheduling the hearing on Defendants’ Motion to Compel Arbitration and Motion
to Dismiss from December 17, 2026 to January 7, 2027 [Dkt. 25], following the hearing on
Plaintiff’s Motion to Remand on the same date.
8. 	Since the hearing on the Motion to Remand is not set until January 7, 2027, I
do not believe the requested one-week extension will have any impact on the schedule for
the case. Defendants’ Opposition would be due October 26, 2026, and Plaintiff’s Reply
would be due November 2, 2026.
I declare under penalty of perjury of the laws of the United States that the foregoing
is true and correct. Executed on this 9th day of October, 2026, in Los Angeles, California.
/s/ Mark D. Kemple
Mark D. Kemple
Case 4:26-cv-10418-HSG Document 27 Filed 10/13/26 Page 6 of 7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
7
JOINT STIPULATION TO EXTEND DEFENDANTS’ TIME TO FILE OPPOSITION TO
PLAINTIFF’S MOTION TO REMAND
ORDER
Pursuant to the Parties’ stipulation, and good cause appearing, IT IS HEREBY
ORDERED that:
1. 	Defendants Salt & Straw, LLC’s, Salt & Straw Inc.’s, and Salt & Straw
Holdings, LLC’s deadline to file an Opposition to Plaintiff’s Motion to
Remand [Dkt. 20] is extended by one week up to and including October 26,
2026; and
2. 	Plaintiff’s Reply in support of the Motion to Remand is due one week
thereafter, on or before November 2, 2026.
IT IS SO ORDERED.
Dated: 10/13/2026
_______________________________
HON. HAYWOOD S. GILLIAM, JR.
United States District Court Judge
Case 4:26-cv-10418-HSG Document 27 Filed 10/13/26 Page 7 of 7