On December 15, 2015 a
Motion-Secondary
was filed
involving a dispute between
Aguayo Abraham,
Dawson Derryck,
Stone Robert,
and
U.S. Security Associates Inc.,
for Other Commercial Complaint (non-tort/non-complex) (General Jurisdiction)
in the District Court of Los Angeles County.
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FILED
Supertor Court of California
PETER R. DION-KINDEM (SBN 95267) County of Los Angeles
JUL 12 2021
THE DION-KINDEM LAW FIRM
PETER R, DION-KINDEM, P.C.
2945 Townsgate Road, Suite 200 ert , executive Ofticer/Clert
Westlake Village, CA 91361 Ail , Depe’
Telephone: (818) 883-4900 zat
Email: peter@dion-kindemlaw.com
5
LONNIE C. BLANCHARD, III (93530)
THE BLANCHARD LAW Group, APC
§211 East Washington Bivd. #2262
Commerce, CA 90040
Telephone: (213) 599-8255
Email: lonnieblanchard@gmail.com
Attorneys for Plaintiffs
10
I
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
COUNTY OF LOS ANGELES
13
14
Robert Stone, Derryck Dawson, and Abraham Case No. BC604257
15 Aguayo on behalf of themselves and all others CLASS ACTION
similarly situated, (Assigned to the Honorable Yvette M.
16 Palazuelos - Dept. 9)
Plaintiffs,
17 Plaintiffs’ Reply Memorandum of Points
vs. and Authorities in Support of Motion for
18
Order Lifting Discovery Stay Entered
1 U.S. Security Associates, Inc., a Delaware August 19, 2020 to Allow Plaintiff Dawson
corporation, and Does | through 10 to Find an Additional Class Representative
20
Defendant. Date: July 19, 2021
21 Time: 10:00 a.m.
2 Dept: 9
23
In Defendant’s summary judgment motion against Plaintiff Aguayo, Defendant contends that he
24
i! is not an adequate class representative because his background check was procured on November 5
rey 25
2013, which was more than two years before the filing of the original complaint in this action
$F
26
(December 15, 2015) and that the parties had agreed that the class members would be limited to those
27
whose background checks were procured on or after two years before the filing of the original action.
28
Plaintiffs’ Reply Memorandum of Points and Authorities in Support of Motion for Order Lifting
Discovery Stay
1
44.92-109091 0719
Document Filed Date
July 12, 2021
Case Filing Date
December 15, 2015
Category
Other Commercial Complaint (non-tort/non-complex) (General Jurisdiction)
Status
Summary Judgment 02/16/2022
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FILED Supertor Court of California PETER R. DION-KINDEM (SBN 95267) County of Los Angeles JUL 12 2021 THE DION-KINDEM LAW FIRM PETER R, DION-KINDEM, P.C. 2945 Townsgate Road, Suite 200 ert , executive Ofticer/Clert Westlake Village, CA 91361 Ail , Depe’ Telephone: (818) 883-4900 zat Email: peter@dion-kindemlaw.com 5 LONNIE C. BLANCHARD, III (93530) THE BLANCHARD LAW Group, APC §211 East Washington Bivd. #2262 Commerce, CA 90040 Telephone: (213) 599-8255 Email: lonnieblanchard@gmail.com Attorneys for Plaintiffs 10 I SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF LOS ANGELES 13 14 Robert Stone, Derryck Dawson, and Abraham Case No. BC604257 15 Aguayo on behalf of themselves and all others CLASS ACTION similarly situated, (Assigned to the Honorable Yvette M. 16 Palazuelos - Dept. 9) Plaintiffs, 17 Plaintiffs’ Reply Memorandum of Points vs. and Authorities in Support of Motion for 18 Order Lifting Discovery Stay Entered 1 U.S. Security Associates, Inc., a Delaware August 19, 2020 to Allow Plaintiff Dawson corporation, and Does | through 10 to Find an Additional Class Representative 20 Defendant. Date: July 19, 2021 21 Time: 10:00 a.m. 2 Dept: 9 23 In Defendant’s summary judgment motion against Plaintiff Aguayo, Defendant contends that he 24 i! is not an adequate class representative because his background check was procured on November 5 rey 25 2013, which was more than two years before the filing of the original complaint in this action $F 26 (December 15, 2015) and that the parties had agreed that the class members would be limited to those 27 whose background checks were procured on or after two years before the filing of the original action. 28 Plaintiffs’ Reply Memorandum of Points and Authorities in Support of Motion for Order Lifting Discovery Stay 1 44.92-109091 0719