Martinez v. E&A Protective Services-Bravo, LLC

Filing 20

ORDER on Notice of Settlement & Joint Stipulation to Request to Vacate All Outstanding Hearings and Deadlines and Request to Set a Hearing Date for Preliminary Approval of Class and Paga Representative Action Settlement, signed by Magistrate Judge Barbara A. McAuliffe on 3/11/2018: Action Settlement Hearing SET for 4/16/2019 at 09:30 AM in Courtroom 5 (DAD) before District Judge Dale A. Drozd.(Hellings, J)

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

ACKERMANN & TILAJEF, P.C.
Craig J. Ackerman, CA Bar No. 229832
[e-mail]
1180 South Beverly Drive, Suite 610
Los Angeles, California 90035
Telephone: [phone]
Facsimile: [phone]
MELMED LAW GROUP P.C.
Jonathan Melmed, CA Bar No. 290218
[e-mail]
1180 South Beverly Drive, Suite 610
Los Angeles, California 90035
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and the Putative Class
LITTLER MENDELSON, P.C.
Alecia W. Winfield, CA Bar No. 209661
Christina M. Cila, CA Bar No. 313226
2049 Century Park East, 5th Floor
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant E & A Protective Services-Bravo, LLC
UNITED STATE DISTRICT COURT

15

EASTERN DISTRICT OF CALIFORNIA

16
17
18
19

CASE NO.: 1:18-cv-00658-DAD-BAM

RICHARD MARTINEZ, an individual, on
behalf of the State of California, as a private
attorney general,

20

[CLASS ACTION]
NOTICE OF SETTLEMENT & JOINT
STIPULATION TO REQUEST TO
VACATE ALL OUTSTANDING
HEARINGS AND DEADLINES AND
REQUEST TO SET A HEARING DATE
FOR PRELIMINARY APPROVAL OF
CLASS AND PAGA REPRESENTATIVE
ACTION SETTLEMENT; ORDER

Plaintiff,
v.

21
22
23
24

E & A PROTECTIVE SERVICES-BRAVO,
LLC, a Virginia Limited Liability Company, and
DOES 1 to 10, inclusive,
Defendant.

25

Complaint Filed: May 14, 2018

26
27
28

1
NOTICE OF SETTLEMENT & JOINT STIPULATION TO REQUEST TO VACATE
ALL OUTSTANDING HEARINGS AND DEADLINES AND REQUEST TO SET A
HEARING DATE FOR PRELIMINARY APPROVAL

1
2
3

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD:
Plaintiff Richard Martinez (“Plaintiff”) and Defendant E & A Protective Services-Bravo, LLC
(“Defendant”) (together referred to herein as the “Parties”), by and through their respective counsel
of record, hereby stipulate as follows:

4

WHEREAS, after a productive exchange of information, and after a full-day mediation, the

5

Parties resolved this matter on a class-wide basis, and, as such, agreed that a class should be certified

6

for the purpose of settlement alone.

7
8

WHEREAS, the Parties have already entered into a Memorandum of Understanding, which
sets forth the basic settlement terms, and are in the process of drafting a long-form Settlement
Agreement and proposed Class Notice for the Court’s review.

9

NOW, THEREFORE, in light of the Parties’ agreement, the Parties hereby request that: (1)

10

all hearings and deadlines be vacated; and (2) the Court schedule a forthcoming hearing on the motion

11

for preliminary approval of class and PAGA representative action settlement, at a date in March 2019.

12
13
14

IT IS SO STIPULATED.
Dated: March 6, 2019

15

/s/ Jonathan Melmed_____________
Jonathan Melmed, Esq.
Craig J. Ackermann, Esq.
Attorneys for Plaintiff

16
17
18
19
20
21
22
23
24
25

Respectfully submitted,
MELMED LAW GROUP P.C.
ACKERMANN & TILAJEF, P.C.

Dated: March 6, 2019

Respectfully submitted,
LITTLER MENDELSON, P.C.
/s/ Christina M. Cila_____________
Christina M. Cila, Esq.
Alecia Winfield, Esq.
Attorneys for Defendant
Local Rule Attestation

Pursuant to Local Rule 131(e) I attest that all of the signatories listed above concur in this
filing’s content and have authorized the filing of this document.
/s/ Jonathan Melmed_____________
Jonathan Melmed, Esq.

26
27
28

2
NOTICE OF SETTLEMENT & JOINT STIPULATION TO REQUEST TO VACATE
ALL OUTSTANDING HEARINGS AND DEADLINES AND REQUEST TO SET A
HEARING DATE FOR PRELIMINARY APPROVAL

1

ORDER

2

Pursuant to the parties’ stipulation and notice of settlement, and for good cause appearing, all

3

hearings and deadlines currently scheduled in this action are HEREBY VACATED. Based on the

4

Court’s availability, a hearing on the motion for preliminary approval of class action settlement is

5

HEREBY SET on April 16, 2019, at 9:30 a.m. in Courtroom 5 (DAD) before District Judge Dale

6

A. Drozd. If the parties will be filing a joint motion, such motion shall be filed 14 days before the

7

hearing; otherwise the parties shall follow the briefing scheduling as stated in Local Rule 230.

8
9
10
11

IT IS SO ORDERED.
Dated:

/s/ Barbara

March 11, 2019

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

_

3
NOTICE OF SETTLEMENT & JOINT STIPULATION TO REQUEST TO VACATE
ALL OUTSTANDING HEARINGS AND DEADLINES AND REQUEST TO SET A
HEARING DATE FOR PRELIMINARY APPROVAL