Gonzalez v. Corrections Corporation of America et al

Filing 58

STIPULATION and ORDER 57 to Continue the Filing Date of Plaintiff's Unopposed Motion for Preliminary Approval of Class Action Settlement, signed by Magistrate Judge Jennifer L. Thurston on 5/10/2019. Motion to be filed by 7/15/2019. (Hall, S)

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PETER R. DION-KINDEM (SBN 95267)
THE DION-KINDEM LAW FIRM
PETER R. DION-KINDEM, P. C.
2945 Townsgate Road, Suite 200
Westlake Village, CA 91361
Telephone: [phone]
Fax:
[phone]
Email:
[e-mail]
LONNIE C. BLANCHARD, III (SBN 93530)
THE BLANCHARD LAW GROUP, APC
3579 East Foothill Blvd., No. 338
Pasadena, CA 91107
Telephone: [phone]
Fax:
[phone]
Email:
[e-mail]

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Attorneys for Plaintiff Jose Gonzalez

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[Additional attorneys listed on following page]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Jose Gonzalez, an individual, on behalf of himself
and all others similarly situated,
Plaintiff,
vs.

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Case No. 1:16-cv-01891-DAD-JLT
Stipulation to Continue the Filing Date of
Plaintiff’s Unopposed Motion for
Preliminary Approval of Class Action
Settlement from May 13, 2019 to June 14,
2019 and [Proposed] Order

CoreCivic of Tennesee, LLC (formerly CCA of
Tennessee, LLC), and Does 1 through 10,
inclusive,

Defendants.
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Stipulation to Continue Filing Date of Motion for Preliminary Approval
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Todd M. Friedman (SBN 216752)
Adrian R. Bacon (SBN 280332)
LAW OFFICES OF TODD M. FRIEDMAN
21550 Oxnard Street, Suite 780
Woodland Hills, California 91367
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff Thomas Richards

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PAUL M. GLEASON State Bar No.: 155569
TOREY FAVAROTE State Bar No.: 198521
4014 Long Beach Blvd., Suite 300
Long Beach, California 90807
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendant
CoreCivic of Tennessee, LLC (formerly
CCA of Tennessee, LLC)

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Stipulation to Continue Filing Date of Motion for Preliminary Approval
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The parties to above-captioned matter, by and through their respective attorneys of record,
hereby stipulate and agree as follows:
WHEREAS, on November 30, 2018, the parties agreed to settle this matter on terms that are
different than those the Court previously refused to accept; and
WHEREAS, because the end of the class period agreed upon by the parties is February 28,
2019, the parties could not obtain complete payroll and time keeping data for currently employed class
members until after that date; and
WHEREAS, on January 22, 2019, the Court ordered the unopposed motion for preliminary
approval of class action settlement to be filed no later than March 29, 2019;
WHEREAS, on March 27, 2019, based on a stipulation submitted by the parties, the Court
continued the deadline for plaintiff to file the motion for preliminary approval to April 29, 2019; and
WHEREAS, since March 27, 2019, Defendant has continued to work diligently to compile time
keeping data through February 28, 2019; and
WHEREAS, compiling the time-keeping data in an electronic format that can be produced to
counsel for Plaintiff has taken longer than anticipated because the electronic time records are contained
in individual spreadsheets for approximately 1200 individuals, which increased the amount of time it
took for Defendant to generate the electronic time records as well as the time it has taken for counsel
for Defendant to review the electronic time records and to format the time records so they can be
produced to Plaintiff’s counsel by removing the employee name on each time record and replacing it
with a DOE designation; and
WHEREAS, counsel for Defendant is now in possession of all the of the electronic time records
and has produced them to Plaintiff’s counsel on April 29, 2019; and
WHEREAS, the time keeping data is necessary for Plaintiffs’ counsel to prepare the unopposed
motion for preliminary approval of class action settlement; and
WHEREAS, the sheer volume of the data within the excel sheets has taken longer than
expected to combine and analyze; and

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Stipulation to Continue Filing Date of Motion for Preliminary Approval
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WHEREAS, the parties agree that it is in each of their best interest to continue the current
deadline for Plaintiffs to file their unopposed motion for preliminary approval of class action settlement
to allow Plaintiffs to analyze the newly-produced data.

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NOW THEREFORE, THE PARTIES STIPULATE and agree that good cause exists to
continue the deadline for Plaintiffs to file their unopposed motion for preliminary approval of class
action settlement to June 14, 2019.
Dated: May 8, 2019

THE DION-KINDEM LAW FIRM

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BY:
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/S PETER R. DION-KINDEM
PETER R. DION-KINDEM, P.C.
PETER R. DION-KINDEM
Attorney for Plaintiff Jose Gonzalez

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Dated: May 8, 2019

GLEASON & FAVAROTE LLP

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BY:
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/S/ PAUL M. GLEASON
PAUL M. GLEASON
TOREY JOSEPH FAVAROTE
Attorneys for Defendant CoreCivic, Inc. formerly
known as Corrections Corporation of America

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Stipulation to Continue Filing Date of Motion for Preliminary Approval
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ORDER
Having reviewed the above Stipulation to Continue the Filing Date of Plaintiff’s Unopposed
Motion for Preliminary Approval of Class Action Settlement and finding good cause for the relief
requested therein, the Court orders that the deadline for Plaintiffs to file their unopposed motion for
preliminary approval of class action settlement is hereby continued to July 15, 2019.
The Court does not anticipate again extending this deadline.

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IT IS SO ORDERED.

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Dated:
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May 10, 2019

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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Stipulation to Continue Filing Date of Motion for Preliminary Approval
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