Opinion
2:18-CV-01280-JAD-EJY
02-02-2023
Kathleen Bliss, on behalf of herself, the Proposed Nationwide Rule 23 Class, and the Proposed Nevada Subclass, Plaintiff, v. CoreCivic, Inc., Defendant.
NICHOLS KASTER, PLLP Matthew H. Morgan Anna P. Prakash Charles A. Delbridge Rebekah L. Bailey Charles J. O'Meara NICHOLS KASTER, PLLP STRUCK LOVE BOJANOWSKI & ACEDO, PLC Anne. M. Orcutt Daniel P. Struck Rachel Love Jacob B. Lee Ashlee B. Hesman Anne M. Orcutt Eden G. Cohen Matthew C. Helland NICHOLS KASTER, LLP Michael Hodgson THE HODGSON LAW FIRM, LLC Lance D. Sandage SANDAGE LAW LLC Joseph K. Eischens LAW OFFICE OF JOSEPH K. EISCHENS Paul S. Padda PAUL PADDA LAW, PLLC PAUL PADDA LAW, PLLC Attorneys for Plaintiff and the Proposed Classes Gina G. Winspear DENNETT WINSPEAR Attorneys for Defendant CoreCivic, Inc
NICHOLS KASTER, PLLP
Matthew H. Morgan
Anna P. Prakash
Charles A. Delbridge
Rebekah L. Bailey
Charles J. O'Meara
NICHOLS KASTER, PLLP
STRUCK LOVE BOJANOWSKI & ACEDO, PLC
Anne. M. Orcutt
Daniel P. Struck
Rachel Love
Jacob B. Lee
Ashlee B. Hesman
Anne M. Orcutt
Eden G. Cohen
Matthew C. Helland
NICHOLS KASTER, LLP
Michael Hodgson
THE HODGSON LAW FIRM, LLC
Lance D. Sandage
SANDAGE LAW LLC
Joseph K. Eischens
LAW OFFICE OF JOSEPH K. EISCHENS
Paul S. Padda
PAUL PADDA LAW, PLLC
PAUL PADDA LAW, PLLC
Attorneys for Plaintiff and the Proposed Classes
Gina G. Winspear
DENNETT WINSPEAR
Attorneys for Defendant CoreCivic, Inc
STIPULATION TO EXTEND DEADLINES (FOURTH REQUEST)
The parties respectfully request that the Court adopt the modifications to the scheduling order set forth below with respect to Defendant's expert disclosures and both parties' class certification briefing:
1. Deadline for Plaintiff to produce Supplemental Declaration from Alexander Wise for use in Plaintiffs class certification briefing set as March 17, 2023.
2. Deadline for Defendant's class certification expert disclosures extended from February 17, 2023 until April 21, 2023.
3. Deadline for completion of class certification expert discovery, which was inadvertently not addressed in the parties' October 14, 2022 Stipulation to Extend Deadlines (Dkt. 216), is extended from November 17, 2022 to May 12, 2023.
4. Class certification briefing schedule modified as proposed in the table below:
Filing Current
Deadline
Proposed New Deadline
Plaintiff's opening class certification brief
March 31, 2023
June 2, 2023
Defendant's class certification response brief
May 1, 2023
July 14, 2023
Plaintiff's class certification reply brief
May 31, 2023
August 14, 2023
This is the fourth request to extend time to file Defendant's expert disclosures and the parties' class certification briefs. (See ECF Nos. 86, 155, and 216 (the parties' previous requests).) The existing case schedule has been in place since October 4, 2021. (ECF No. 156.) Since that time, the parties have made significant progress on discovery necessary for class certification. However, the primary outstanding discovery that is relevant to class certification is from third-party telephone vendors. The parties make this request because they are still working to obtain complete data productions from multiple telephone vendors. Securus has agreed to produce, but has not yet begun production of, call data from 16 facilities. Counsel for Securus anticipates that the production will take approximately two weeks. GTL has made two productions to date, but during the 30(b)(6) deposition of the GTL designee, it became apparent that there is additional GTL call data to produce for La Palma Correctional Center, Saguaro Correctional Center, and Northeast Ohio Correctional Center, as well as a potential re-production of call data from Marion County Jail II. GTL's counsel is still confirming the scope of additional production/re-production and has not yet provided a timeframe. Following the Securus production, the parties will need to depose a vendor representative from Securus regarding the call data, and the parties will need time to review the data from both vendors and incorporate it into their analyses.
IT IS SO ORDERED: