Richards v. CoreCivic of Tennessee, LLC

Filing 38

STIPULATION and ORDER 36 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 5/17/2019. Motion filing deadline 7/15/2019. (Hall, S)

1
2
3
4
5
6
7

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]
Attorneys for Plaintiff Thomas Richards

8
9
10
11

[Additional attorneys listed on following page]
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

12
13
14
15
16
17
18
19
20

THOMAS RICHARDS, individually
and on behalf of all others similarly
situated,

)
)
)
)
Plaintiff,
)
)
v.
)
)
CORECIVIC OF TENNESSEE, LLC, )
)
Defendants.
)
_______________________________ )

CASE NO.: 1:17-cv-01094-LJO-JL
Consolidated case number:
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
March 29, 2019 to July 15, 2019
and [Proposed] Order

21
22
23
24
25
26
27
28

pg. 1 Stipulation and Order to Continue Filing Date of Motion for Preliminary Approval

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17

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]
Email: [e-mail]
Attorneys for Plaintiff Jose Gonzalez
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]
Attorneys for Defendant
CoreCivic of Tennessee, LLC (formerly CCA of Tennessee, LLC)

18
19
20
21
22
23
24
25
26
27
28

pg. 2 Stipulation and Order to Continue Filing Date of Motion for Preliminary Approval

1

The parties to above-captioned matter, by and through their respective

2
3

attorneys of record, hereby stipulate and agree as follows:
WHEREAS, on November 30, 2018, the parties to this matter and the matter

4
5

entitled Jose Gonzalez vs. CoreCivic of Tennessee, LLC, Case No 1:16-cv-01891-

6
7
8

DAD-JLT (the “Gonzalez matter”), agreed to a settlement of both cases on terms
different from those that the Court previously refused to accept; and

9

WHEREAS, on May 8, 2019, the parties to the Gonzalez matter filed a

10
11

document entitled “Stipulation to Continue the Filing Date of Plaintiff’s

12

Unopposed Motion for Preliminary Approval of Class Action Settlement from
13
14
15

May 13, 2019 to June 14, 2019 and [Proposed] Order,” hereinafter referred to as
the “Stipulation,” a true and correct copy of which is attached hereto as Exhibit A;

16
17
18

and
WHEREAS, on May 10, 2019, this Court issued an Order granting the

19
20
21
22

request by the parties to the Gonzalez matter to continue the deadline for Plaintiff
to file his unopposed motion for preliminary approval of class action settlement
and extended the deadline to July 15, 2019, a true and correct copy of which is

23
24

attached hereto as Exhibit B; and

25
26
27
28

pg. 3 Stipulation and Order to Continue Filing Date of Motion for Preliminary Approval

1

WHEREAS, for the identical reasons set forth in the May 8, 2019

2
3
4
5

Stipulation in the Gonzalez matter, the parties to this matter agree that it is in each
of their best interest to continue the deadline for Plaintiff to file his motion for
preliminary approval to July 15, 2019.

6
7
8

NOW THEREFORE, THE PARTIES STIPULATE and agree that good
cause exists to continue the deadline for Plaintiff to file his unopposed motion for

9
10

preliminary approval of class action settlement to July 15, 2019.

11
12

Dated: May 15, 2019

Law Offices of Todd. M. Friedman

13

s/Adrian R. Bacon
Adrian R. Bacon
Attorneys for Plaintiff Thomas Richards

14
15
16
17
18
19
20
21

Dated: May 15, 2019

Gleason & Favarote, LLP
s/Paul M. Gleason
Paul M. Gleason
Torey Joseph Favarote
Attorneys for Defendant CoreCivic of Tennessee,
LLC

22
23
24
25
26
27
28

pg. 4 Stipulation and Order to Continue Filing Date of Motion for Preliminary Approval

1

ORDER

2
3
4
5

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

6
7
8

deadline for Plaintiff to file his unopposed motion for preliminary approval of class
action settlement is hereby continued to July 15, 2019.

9
10
11
12
13

IT IS SO ORDERED.
Dated:

May 17, 2019

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

pg. 5 Stipulation and Order to Continue Filing Date of Motion for Preliminary Approval