Dietrick v. Securitas Security Services USA, Inc.

Filing 143

STIPULATION AND ORDER re 142 STIPULATION WITH PROPOSED ORDER Regarding Settlement filed by Michael Deatrick. Signed by Judge Jon S. Tigar on August 6, 2015. (wsn, COURT STAFF) (Filed on 8/6/2015)

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1 2 3 4 5 6 7 8 9 10 EDUARDO G. ROY (Bar No. 146316) DANIEL C. QUINTERO (Bar No. 196492) JILL DESSALINES (Bar No. 123825) JOHN R. HURLEY (Bar No. 203641) PROMETHEUS PARTNERS L.L.P. 220 Montgomery Street Suite 1094 San Francisco, CA 94104 Telephone: 415.527.0255 Attorneys for Plaintiffs Michael Deatrick, et al. SHERRY B. SHAVIT, ESQ.; STATE BAR NO.: 193222 STUART E. COHEN, ESQ.; STATE BAR NO.: 213810 THARPE & HOWELL, LLP 15250 Ventura Blvd., Ninth Floor Sherman Oaks, CA 91403 Tel: (818) 205-9955 Fax: (818) 205-9944 11 12 13 14 15 16 17 J. KEVIN LILLY, ESQ.; STATE BAR NO.: 119981 LITTLER MENDELSON PC 2049 Century Park East, 5th Floor Los Angeles, CA 90067 Tel: (310) 553-0308 Fax: (310) 553-5583 Attorneys for Defendant, SECURITAS SECURITY SERVICES, USA, INC. 18 UNITED STATES DISTRICT COURT 19 NORTHERN DISTRICT OF CALIFORNIA 20 21 22 MICHAEL DEATRICK, individually and on behalf of all others similarly situated, and as representative of the State of California, et al. Plaintiff, 23 24 25 26 Case No.: 3:13-cv-5016 JST STIPULATION AND [PROPOSED] ORDER REGARDING SETTLEMENT v. SECURITAS SECURITY SERVICES USA, INC., Defendant. 27 28 1 STIPULATION REGARDING SETTLEMENT Case no. 3:13-cv-5016 JST 1 2 3 Plaintiffs Michael Deatrick, the Opt-in Plaintiffs, and Defendant Securitas Security Services USA, Inc. (“Securitas USA”) hereby stipulate and agree as follows: WHEREAS, the parties submitted a STIPULATION AND [PROPOSED] ORDER 4 REGARDING SETTLEMENT AND VACATING MOTION DATES [ECF 140] on June 16, 2015, 5 informing that Court that they had reached agreement on the general terms of settlement in this action. 6 7 8 9 10 11 12 WHEREAS, the Court accepted the Parties’ stipulation and ordered [ECF 141] that a motion for approval be submitted by August 7, 2015. WHEREAS, the parties have been working diligently to negotiate additional necessary terms and finalize a settlement agreement. WHEREAS, due to the number and complexity of issues the parties require additional time to document the settlement and submit a motion for approval. The Parties THEREFORE STIPULATE, AGREE AND REQUEST AS FOLLOWS: 13 1. That the Court continue the current deadline of August 7, 2015, for the Plaintiffs to file a 14 motion for conditional certification of a settlement class or classes and for preliminary 15 approval of settlement to August 21, 2015. 16 Pursuant to Local Rule 5-1(i)(3), the undersigned filer of this document hereby attests that 17 concurrence in the filing has been obtained from each of the other signatories, which shall serve in lieu 18 of their signatures on the document. 19 20 21 IT IS SO STIPULATED. 22 DATED: August 6, 2015 Respectfully submitted, 23 PROMETHEUS PARTNERS L.L.P. 24 25 By: 26 27 /s/ John R. Hurley John R. Hurley, Esq. Attorneys for Plaintiffs Michael Deatrick, et al. 28 2 STIPULATION REGARDING SETTLEMENT Case no. 3:13-cv-5016 JST 1 DATED: August 6, 2015 Respectfully submitted, 2 THARPE & HOWELL, LLP 3 4 By: 5 6 PURSUANT TO STIPULATION, IT IS SO ORDERED. 8 August 6, 2015 RT 14 J u d ge J o ER H 15 16 nS R NIA Jon S. Tigar United States District . TigaJudge Court r NO 13 By: FO 12 DERED O OR IT IS S LI 11 UNIT ED 10 S DISTRICT TE C TA RT U O S 9 DATED: A 7 /s/ Sherry B. Shavit Sherry B. Shavit, Esq. Attorneys for Defendant Securitas Security Services USA, Inc. N F D IS T IC T O R C 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION REGARDING SETTLEMENT Case no. 3:13-cv-5016 JST

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