Hernandez v. Global Prisoner Services, LLC D/b/a Texas Prisoner Transportation Services

Western District of Texas, txwd-5:2019-cv-00374

STATUS REPORT JOINT by Global Prisoner Services, LLC, Ryan Whitten.

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DISTRICT AMANDA HERNANDEZ, individually and) on behalf of All Others Similarly Situated,))) Plaintiff,)) No.: 5:19-cv-00374-FB v.)) GLOBAL PRISONER SERVICES, LLC) d/b/a TEXAS PRISONER) TRANSPORTATION SERVICES, PTS OF)) AMERICA, LLC, and RYAN WHITTEN,)) Defendants.)) JOINT STATUS REPORT Counsel for the parties apologize to the Court for having missed the December 26, 2019 status update deadline, and note their appreciation for the Court's patience. During the stay, Global Prisoner Services, LLC provided various payroll and activity information to Plaintiffs' counsel. In turn, Plaintiffs' counsel has discussed the matters at issue with his clients, though such communications were not easily had given the proximity to the holidays. As of January 3, 2020, Plaintiffs have provided to the Defendants a global settlement demand. Defendants anticipate being able to respond quickly. Accordingly, the parties request until the morning of January 20, 2020 to advise the Court whether a settlement has been reached. During that time, the parties request that all matters remain stayed. Furthermore, the parties have discussed whether there will be any opposition to arbitration in this case. Plaintiff's counsel believes that, as a product of the negotiations surrounding a possible settlement, an agreement upon arbitration is likely to be reached if the case should not be resolved by other means first. 1 Should the Court request additional information from the parties, counsel are more than happy to provide the same to the Court. Respectfully submitted, /S/ Sean C. Wlodarczyk Sean C. Wlodarczyk (TN Bar No. 30410) Admitted Pro Hac Vice for this Matter, pending completion of admission to the Western District of Texas. CORNELIUS & COLLINS, LLP Suite 1500, Nashville City Center 511 Union Street P. O. Box 190695 Nashville, Tennessee 37219 (615) 244-1440 Attorney for Global Prisoner Services, LLC and Ryan Whitten /S/ Curt Hesse (by permission Sean C. Wlodarczyk) Melissa Moore (24013189) Curt Hesse (24065414) Moore & Associates Lyric Centre 440 Louisiana Street, Suite 675 Houston, TX 77002 Attorneys for Plaintiff Amanda Hernandez S/Gregory J. Northen (by permission Sean C. Wlodarczyk) Mary E. Buckley (24101571) Gregory J. Northen, (Ark Bar #20111891) Admitted Pro Hac Vice Cross, Gunter, Witherspoon & Galchus, PC 500 President Clinton Avenue, Suite 200 Little Rock, AR 72201 Attorneys for PTS of America, LLC 2 CERTIFICATE OF SERVICE I do hereby certify that a true and exact copy of the foregoing has been served by the PACER/ECF system on this 3rd day of January, 2020 upon the following: Melissa Moore (24013189) Mary E. Buckley (24101571) Curt Hesse (24065414) Gregory J. Northen, (Ark Bar #20111891) Moore & Associates Cross, Gunter, Witherspoon & Galchus, PC Lyric Centre 500 President Clinton Avenue, Suite 200 440 Louisiana Street, Suite 675 Little Rock, AR 72201 Houston, TX 77002 /S/ Sean C. Wlodarczyk Sean C. Wlodarczyk 3