Yee v. Moneylion Technologies Inc.

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STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
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TROUTMAN
 PEPPER
 LOCKE
 LLP
100
 SPECTRUM
 CENTER
 DRIVE
SUITE
 1500
IRVINE
, CA
 92618
TROUTMAN PEPPER LOCKE LLP
Chloe Ann C. Lee (SBN 351040)
chloeann.lee@troutman.com
100 Spectrum Center Drive, Suite 1500
Irvine, CA 92618
Telephone: 949.622.2700
Facsimile: 949.622.2739
Attorney for Defendant
MONEYLION TECHNOLOGIES INC.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
DANIEL YEE, on behalf of himself and all
others similarly situated,
Plaintiff,
vs.
MONEYLION TECHNOLOGIES INC., a
Delaware corporation, and Does 1 to 100,
inclusive,
Defendant.
Case No. 3:26-cv-7322CRB
JOINT STIPULATION TO CONTINUE
INITIAL CASE MANAGEMENT
CONFERENCE
Judge: Hon. Charles R. Breyer
Current Conference Date: October 30, 2026
New Conference Date: 14 days after Court
Rules on Motion to Dismiss
Current Statement Date: October 23, 2026
New Statement Date: 7 days before New
Conference Date
: ORDER
Case 3:26-cv-07322-CRB Document 19 Filed 10/08/26 Page 1 of 5

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STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
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TROUTMAN
 PEPPER
 LOCKE
 LLP
100
 SPECTRUM
 CENTER
 DRIVE
SUITE
 1500
IRVINE
, CA
 92618
Pursuant to L.R. 6-1(b) and 6-2 Defendant Moneylion Technologies Inc. (“Defendant”)
and Plaintiff Daniel Yee (“Plaintiff”), by and through undersigned counsel, hereby jointly
stipulate and agree as follows:
1. On June 1, 2026, Plaintiff filed a Complaint in the Superior Court of the State of
California for the County of Contra Costa, styled Daniel Yee, on behalf of himself and all others
similarly situated v. Moneylion Technologies Inc., a Delaware Corporation, Case No. C26-01862.
2. On July 16, 2026, Defendant timely filed a Notice of Removal removing the state
court action to this Honorable Court. ECF No. 1.
3. On July 24, 2026, this Court set the case management conference for October 30,
2026, with the case management statement due by October 23, 2026. ECF No. 12.
4. On September 21, 2026, Defendant filed a motion to dismiss the operative
complaint. ECF No. 13.
5. On October 6, 2026, Plaintiff filed a Notice of Election to File First Amended
Complaint as of Right in Lieu of Opposition. ECF NO. 17. Plaintiff informed the Court that
Plaintiff intended to file the First Amended Class Complaint on or before October 12, 2026, in lieu
of filing a merits opposition to a motion directed at a pleading that Plaintiff is amending as of right.
6. The parties filed their ADR Certifications on September 28 and September 29. ECF
Nos. 15, 16.
7. On October 1, 2026, counsel for the parties met and conferred via videoconference
in advance of the initial case management conference. Both parties agreed that both the Rule 26(f)
conference and the initial case management conference should be continued until after the Court
has ruled on the pending Motion to Dismiss.
8. Continuing the initial case management conference is in the interest of all parties
will save the time and resources of all parties and the Court because the Motion to Dismiss may
narrow the legal issues in this litigation, even if the Court declines to grant the Motion to Dismiss
in its entirety.
//
//
Case 3:26-cv-07322-CRB Document 19 Filed 10/08/26 Page 2 of 5

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STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
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TROUTMAN
 PEPPER
 LOCKE
 LLP
100
 SPECTRUM
 CENTER
 DRIVE
SUITE
 1500
IRVINE
, CA
 92618
Accordingly, the parties respectfully request the Court modify its initial scheduling order as
follows:
1. The initial case management conference be continued from October 30, 2026, to
fourteen (14) days after the final Order on Defendant’s Motion to Dismiss, or to any date thereafter
that is convenient for the Court.
2. Any deadline conditioned upon the date of the initial scheduling conference,
including the deadlines the parties to conduct Rule 26(f) conference, make their Rule 26(a)(1)
disclosures, and to submit the Joint Case Management Statement, be vacated and reset based upon
the continued initial case management conference date.
Case 3:26-cv-07322-CRB Document 19 Filed 10/08/26 Page 3 of 5

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STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
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TROUTMAN
 PEPPER
 LOCKE
 LLP
100
 SPECTRUM
 CENTER
 DRIVE
SUITE
 1500
IRVINE
, CA
 92618
Dated: October 7, 2026
TROUTMAN PEPPER LOCKE LLP
By: /s/ Chloe Ann Lee
Chloe Ann Lee
Attorney for Defendant Moneylion
Technologies Inc.
Dated: October 7, 2026 POTTER HANDY LLP
By: /s/ Naomi Butler (authorized by email
dated October 6, 2026
Mark D. Potter
James M. Treglio
Isabel Rose Masanque
Naomi Butler
Attorneys for Plaintiff Daniel Yee
SIGNATURE ATTESTATION
I, Chloe Ann Lee, hereby attest that each of the other Signatories has concurred in the
filing of the document.
DATE: October 7, 2026 By: /s/ Chloe Ann Lee
Chloe Ann Lee
Case 3:26-cv-07322-CRB Document 19 Filed 10/08/26 Page 4 of 5

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[PROPOSED] ORDER STIPULATION TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE
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TROUTMAN
 PEPPER
 LOCKE
 LLP
100
 SPECTRUM
 CENTER
 DRIVE
SUITE
 1500
IRVINE
, CA
 92618
[PROPOSED] ORDER
Pursuant to the parties’ Stipulation, and good cause appearing, the Court orders the
following:
The initial case management conference is hereby continued from October 30, 2026, to
fourteen (14) days after the final Order on Defendant’s Motion to Dismiss.
Any deadline conditioned upon the date of the initial scheduling conference, including the
deadlines the parties to conduct Rule 26(f) conference, make their Rule 26(a)(1) disclosures, and
to submit the Joint Case Management Statement, is hereby vacated and reset based upon the
continued initial case management conference date.
The September 8, 2026 deadlines for Rule 26(a)(1) initial disclosures and the Joint Case
Management Statement, and the ADR certification deadline, are hereby vacated.
All other deadlines shall be based upon the new date for the initial case management
conference.
IT IS SO ORDERED
Dated: October ______, 2026
The Honorable Charles R. Breyer
U.S. District Judge
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Case 3:26-cv-07322-CRB Document 19 Filed 10/08/26 Page 5 of 5