Haralson v. U.S. Aviation Services Corp. et al
Filing
47
STIPULATION AND ORDER re 46 STIPULATION WITH PROPOSED ORDER COMPELLING THE PRODUCTION OF A CLASS LIST filed by U.S. Aviation Services Corp. Signed by Judge Jon S. Tigar on June 19, 2017. (wsn, COURT STAFF) (Filed on 6/19/2017)
1
2
3
4
5
6
7
SETAREH LAW GROUP
Shaun Setareh (SBN 204514)
shaun@setarehlaw.com
Thomas Segal (SBN 222791)
thomas@setarehlaw.com
H. Scott Leviant (SBN 200834)
scott@setarehlaw.com
9454 Wilshire Boulevard, Suite 907
Beverly Hills, California 90212
Telephone: (310) 888-7771
Facsimile:
(310) 888-0109
Attorneys for Plaintiff
JAMES HARALSON
8
9
10
11
12
13
14
VEDDER PRICE (CA), LLP
Brendan Dolan (SBN 126732)
bdolan@vedderprice.corn
Christopher A. Braham (293367)
cbraham@vedderprice.com
275 Battery Street, Suite 2464
San Francisco, California 94111
Telephone: (415) 749-9500
Facsimile:
(415) 749-9502
Attorneys for Defendant
U.S. AVIATION SERVICES CORP.
15
16
UNITED STATES DISTRICT COURT
17
NORTHERN DISTRICT OF CALIFORNIA
18
19
JAMES HARALSON, on behalf of himself and
others similarly situated,
20
Plaintiff,
21
v.
22
24
PLAINTIFF JAMES HARALSON’S
AND DEFENDANT U.S. AVIATION
SERVICES CORP.’S STIPULATION
FOR AN ORDER COMPELLING THE
PRODUCTION OF A CLASS LIST
U.S. AVIATION SERVICES CORP., a Nevada
corporation; UNITED AIRLINES, INC., a
Delaware corporation; and DOES 1-50,
inclusive,
25
Case No. 3:16-cv-05207
Defendants.
23
26
27
28
STIPULATION FOR AN ORDER
COMPELLING THE PRODUCTION OF A
CLASS LIST
VEDDER PRICE (CA), LLP
ATTORNEYS AT LAW
LOS ANGELES
LOS_ANGELES/#27415.3
1
IT IS HEREBY STIPULATED by and between Plaintiff James Haralson (“Plaintiff”) and
2
Defendant U.S. Aviation Services Corp. (“U.S. Aviation”) (collectively the “Parties”) by and
3
through their respective counsel of record, that:
4
WHEREAS, on December 7, 2016, Plaintiff propounded an Interrogatory on U.S.
5
Aviation requesting it to provide the name, mailing address, cellular telephone number, email
6
address and job title for each putative class member (hereafter known as a request for a “Class
7
List”);
8
WHEREAS, on April 4, 2017, U.S. Aviation objected to Plaintiff’s Interrogatory
9
primarily on the grounds that such a request for a Class List is premature prior to Plaintiff
10
satisfying his prima facie burden showing that the Federal Rule of Civil Procedure 23 class action
11
requirements are met and the dissemination of a Class List violates the privacy rights of U.S.
12
Aviation former and current employees;
13
14
WHEREAS, on April 11, 2017, Plaintiff sent U.S. Aviation a meet and confer letter
arguing its position as to why U.S. Aviation’s initial discovery response was deficient;
15
WHEREAS, on April 28, 2017, after the Parties engaged in good faith meet and confer
16
discussions, and based on the legal authorities presented by Plaintiff U.S. Aviation agreed to
17
produce the requested Class List subject to an Order from this Court requiring it do so;
18
THEREFORE, the parties hereby stipulate and jointly request that the Court enter this
19
Order requiring U.S. Aviation to produce a Class List and instructing Plaintiff’s counsel to protect
20
the privacy interest of putative class members as follows:
21
1.
U.S. Aviation is required to produce the name, last known mailing address, last
22
known cellular telephone number if in possession of U.S. Aviation, last known
23
personal email address if in possession of U.S. Aviation and last known job title
24
held at U.S. Aviation for each putative class member, with putative class member
25
defined as all persons employed by Defendant U.S. Aviation Services Corp. in
26
hourly paid or non-exempt positions as aircraft cleaners in California since
27
September 9, 2012;
28
VEDDER PRICE (CA), LLP
-2-
ATTORNEYS AT LAW
LOS ANGELES
LOS_ANGELES/#27415.3
STIPULATION FOR AN ORDER
COMPELLING THE PRODUCTION OF A
CLASS LIST
1
2.
Unless the Parties agree to a different date, the deadline for U.S. Aviation to
2
produce the Class List shall be within thirty (30) days of the entry of this Court’s
3
order;
4
3.
Plaintiff’s counsel must inform each putative class member that Plaintiff’s counsel
5
contacts that he or she has a right not to talk to Plaintiff’s counsel and that, if he or
6
she declines to talk with Plaintiff’s counsel, Plaintiff’s counsel will immediately
7
terminate the conversation and will not contact that individual again.
8
Dated: June 15, 2017
SETAREH LAW GROUP
9
By: /s/ H. Scott Leviant
Shaun Setareh
Thomas Segal
H. Scott Leviant
10
11
12
Attorneys for Plaintiff
JAMES HARALSON
13
14
Dated: June 15, 2017
VEDDER PRICE (CA), LLP
15
By: /s/ Christopher A. Braham
Brendan Dolan
Christopher A. Braham
16
17
Attorneys for Defendant
U.S. AVIATION SERVICES, CORP.
18
19
ORDER
20
21
Good cause appearing therefor, IT IS SO ORDERED.
22
23
June 19, 2017
Dated: __________________________
THE HONORABLE JON S. TIGAR
24
25
26
27
28
VEDDER PRICE (CA), LLP
-3-
ATTORNEYS AT LAW
LOS ANGELES
LOS_ANGELES/#27415.3
STIPULATION FOR AN ORDER
COMPELLING THE PRODUCTION OF A
CLASS LIST
1
2
3
4
ATTESTATION PURSUANT TO LOCAL RULE 5-1(i)(3)
I, Christopher A. Braham, attest that concurrence in the filing of this stipulation has been
obtained from all signatories.
Executed this 15th day of June 2017, in Los Angeles, California.
5
/s/ Christopher A. Braham
Christopher A. Braham
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
VEDDER PRICE (CA), LLP
-4-
ATTORNEYS AT LAW
LOS ANGELES
LOS_ANGELES/#27415.3
STIPULATION FOR AN ORDER
COMPELLING THE PRODUCTION OF A
CLASS LIST
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?