Hughes v. TVI, Inc.

Filing 21

STIPULATION and ORDER signed by Senior District Judge William B. Shubb on 1/28/2025 CONTINUING Class Certification Deadlines as follows: Plaintiff deadline to file a Motion for Class Certification on 7/31/2025; Defendant's Opposition due by 9/5/2025; Plaintiff's Reply due by 9/26/2025. (Deputy Clerk OML)

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1 2 3 4 5 6 7 8 9 10 11 12 13 Adam Y. Siegel (SBN 238568) Adam.Siegel@jacksonlewis.com JACKSON LEWIS P.C. 725 South Figueroa Street, Suite 2500 Los Angeles, California 90017-5408 Telephone: (213) 689-0404 Facsimile: (213) 689-0430 Attorneys for Defendant TVI, INC. BRANDON BROUILLETTE (SBN 273156) bbrouillette@crosnerlegal.com CHAD SAUNDERS (SBN 257810) chad@crosnerlegal.com ZACHARY M. CROSNER (SBN 272295) zach@crosnerlegal.com CROSNER LEGAL, PC 9440 Santa Monica Blvd. Suite 301 Beverly Hills, CA 90210 Tel: (866) 276-7637 Fax: (310) 510-6429 14 15 Attorneys for Plaintiff Shea Hughes 16 UNITED STATES DISTRICT COURT 17 FOR THE EASTERN DISTRICT OF CALIFORNIA 18 19 SHEA HUGHES, an individual, and on 20 behalf of all others similarly situated, Plaintiff, 21 22 v. CASE NO.: _2:24-00250-WBS-AC STIPULATION AND ORDER TO CONTINUE CLASS CERTIFICATION DEADLINES 23 TVI, INC., a Washington Corporation; and DOES 1-100, inclusive, 24 Defendants. 25 Complaint Filed: Trial Date: November 28, 2023 May 19, 2026 26 27 28 Case No.: 2:24-00250-WBS-AC 1 STIPULATION AND ORDER TO CONTINUE CLASS CERTIFATION DEADLINES 1 2 Plaintiff Shea Hughes (“Plaintiff”) and Defendant TVI, INC. (“Defendant”), by and through their counsel of record, hereby stipulate and agree as follows: 3 WHEREAS, on November 28, 2023, Plaintiff Shea Hughes filed a Class Action 4 Complaint against Defendant in the Superior Court of the State of California – County of 5 Solano, Case No. CU23-5586 (“Hughes Class Action”); 6 WHEREAS, at or around the time Plaintiff filed the Class Action Complaint in 7 Solano County, Plaintiff filed a separate Complaint against Defendant for penalties under 8 the Private Attorneys General Act in Solano County, Case No. CU23-05591 (“Hughes 9 PAGA Action”); 10 11 WHEREAS, Defendant removed the Hughes Class Action, and the Hughes PAGA Action remains pending in Superior Court; 12 WHEREAS, Defendant filed a notice of related cases identifying the class action 13 case entitled Jose Villanueva v. TVI, Inc., et al.; Northern District of California Case No. 14 5:24-cv-01649 (“Villanueva Class Action”), as a related case; 15 16 17 18 19 20 21 22 WHEREAS, the Parties agreed to participate in a global mediation for the Hughes Class Action, the Hughes PAGA Action, the Villanueva Class Action; WHEREAS, the global mediation occurred on January 24, 2025, and resulted in a mediator’s proposal to which the Parties must respond on or before January 31, 2025; WHEREAS, the Court set a class certification filing deadline for the Hughes Class Action for January 31, 2025 (Doc. 19); and WHEREAS, to preserve the Parties and the Court’s resources, the Parties agree, and respectfully request, to continue the class certification deadlines by six months. 23 IT IS HEREBY STIPULATED by and between Plaintiff and Defendant as follows: 24 1. Plaintiff’s deadline to file a motion for class certification shall be continued until 25 July 31, 2025. 26 2. Defendant’s opposition shall be due by September 5, 2025. 27 3. Plaintiff’s reply shall be due by September 26, 2025. 28 Case No.: 2:24-00250-WBS-AC 2 STIPULATION AND ORDER TO CONTINUE CLASS CERTIFATION DEADLINES 1 IT IS SO STIPULATED 2 3 Dated: January 28, 2025 JACKSON LEWIS P.C. 4 5 By: /s/ Adam Y. Siegel (as authorized 1/24/25) Adam Y. Siegel 6 Attorneys for Defendant TVI, INC 7 8 9 Dated: January 28, 2025 CROSNER LEGAL, P.C. 10 By: 11 /s/ Chad Saunders Chad Saunders 12 Attorneys for Plaintiff Shea Hughes 13 14 ORDER 15 16 17 18 Pursuant to the Parties’ stipulation, the Court hereby Orders as follows: 1. Plaintiff’s deadline to file a motion for class certification shall be continued until July 31, 2025. 19 2. Defendant’s opposition shall be due by September 5, 2025. 20 3. Plaintiff’s reply shall be due by September 26, 2025. 21 22 23 Dated: January 28, 2025 24 25 26 27 28 Case No.: 2:24-00250-WBS-AC 3 STIPULATION AND ORDER TO CONTINUE CLASS CERTIFATION DEADLINES

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