Pryor v. Securitas Critical Infrastructure Services, Inc.

JOINT STIPULATION TO CONTINUE MOTION TO COMPEL ARBITRATION AND RELATED DEADLINES
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Frank A. Magnanimo (SBN 174570)
E-Mail: fmagnanimo@fisherphillips.com
Jasmine R. Kiaei (SBN 331080)
E-Mail: jkiaei@fisherphillips.com
Madison A. Osorio (SBN: 333982)
E-Mail: maosorio@fisherphillips.com
FISHER & PHILLIPS LLP
21600 Oxnard Street, Suite 700
Woodland Hills, California 91367
Telephone: (213) 330-4500
Facsimile: (213) 330-4501
Attorneys for Defendant
SECURITAS CRITICAL INFRASTRUCTURE SERVICES, INC.
James R. Hawkins (SBN 192925)
E-Mail: james@jameshawkinsaplc.com
Ava Issary (SBN 342252)
E-Mail: ava@jameshawkinsaplc.com
Lauren Falk (SBN 316893)
E-Mail: lauren@jameshawkinsaplc.com
JAMES HAWKINS APLC
9880 Research Drive, Suite 200
Irvine, CA 92618
Attorneys for Plaintiff
ROBERT PRYOR
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA
ROBERT PRYOR,
Plaintiff,
v.
SECURITAS CRITICAL
INFRASTRUCTURE SERVICES, INC.,
Defendant.
Case No.: 2:25-cv-02862-TLN-JDP (Lead Case)
Consolidated with: 2:25-cv-2165-TLN-JDP
JOINT STIPULATION TO CONTINUE
DEFENDANT’S MOTION TO COMPEL
ARBITRATION, STRIKE CLASS CLAIMS
AND STAY PROCEEDINGS, AND
RELATED DEADLINES; ORDER
Complaint Filed: 	July 24, 2025
Removed: 	October 3, 2025
Trial Date: 	Not Set
Case 2:25-cv-02862-TLN-JDP Document 29 Filed 10/15/26 Page 1 of 5

JOINT STIPULATION TO CONTINUE MOTION TO COMPEL ARBITRATION AND RELATED DEADLINES
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Plaintiff Robert Pryor (“Plaintiff”) and Defendant Securitas Critical Infrastructure Services,
Inc. (“Defendant”) (collectively, the “Parties”), by and through their respective counsel of record,
hereby stipulate and respectfully request that the Court continue Defendant’s Motion to Compel
Arbitration, Strike Class Claims and Stay Proceedings, and related deadlines, in light of the Parties
upcoming private mediation of this matter.
Good cause exists for the requested modification pursuant to Federal Rule of Civil
Procedure 16(b)(4), as follows:
RECITALS
1. 	On June 10, 2026, Defendant filed a Motion to Compel Arbitration, Strike Class
Claims and Stay Proceedings (“Motion”). (Docket No. 23).
2. 	Defendant’s Motion to Compel Arbitration remains pending before the Court. The
hearing on Defendant’s Motion was vacated. Pursuant to Docket No. 25, Plaintiff’s deadline to file
his Opposition to the Motion is October 16, 2026 while Defendant’s deadline to file its reply in
support of the Motion is October 23, 2026. The Court has not yet set a hearing date for Defendant’s
Motion.
3. 	The Parties have agreed to participate in private mediation with mediator Steve
Mehta and have scheduled mediation for February 4, 2027. The Parties intend to participate in the
mediation in good faith in an effort to resolve this action without the need for further litigation.
4. 	Continuing the existing Motion deadlines (and any hearing date the Court intends to
set), including Plaintiff’s Opposition and Defendant’s Reply, will preserve Defendant’s asserted
arbitration rights, permit the Court to resolve the threshold arbitrability issues presented by the
pending Motion, and allow the Parties to focus their resources on the upcoming mediation.
5. 	Absent a continuance, the Parties would be required to proceed with their respective
Opposition and Reply to the Motion and take time and resources away from preparing for a
productive mediation. Such Motion work may ultimately prove unnecessary depending upon
whether mediation is successful. A continuance therefore will conserve the resources of the Parties
and the Court and avoid potentially unnecessary litigation expenses.
6. 	The requested continuance is not sought for purposes of delay. Rather, the Parties
Case 2:25-cv-02862-TLN-JDP Document 29 Filed 10/15/26 Page 2 of 5

JOINT STIPULATION TO CONTINUE MOTION TO COMPEL ARBITRATION AND RELATED DEADLINES
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seek to preserve their respective rights, avoid unnecessary litigation expenses, and promote the
efficient resolution of this action.
7. 	Accordingly, the Parties respectfully request that the Court continue the Plaintiff’s
Opposition deadline and Defendant’s Reply deadline to a date 90 days following the February 4,
2027 mediation, or a date thereafter that is convenient to the Court.
STIPULATION
IT IS HEREBY STIPULATED AND AGREED, subject to the Court’s approval, that the
Plaintiff’s Opposition deadline and Defendant’s Reply deadline to its Motion to Compel Arbitration
be continued as set forth above.
Dated: October 15, 2026 	FISHER & PHILLIPS LLP
By: /s/ Jasmine r. Kiaei (with permission)
Frank A. Magnanimo
Jasmine R. Kiaei
Madison A. Osorio
Attorneys for Defendant
SECURITAS CRITICAL INFRASTRUCTURE
SERVICES, INC.
Dated: October 15, 2026 	JAMES HAWKINS APLC
By:
James R. Hawkins
Ava Issary
Lauren Falk
Attorneys for Plaintiff
ROBERT PRYOR
Case 2:25-cv-02862-TLN-JDP Document 29 Filed 10/15/26 Page 3 of 5

JOINT STIPULATION TO CONTINUE MOTION TO COMPEL ARBITRATION AND RELATED DEADLINES
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ATTESTATION REGARDING ELECTRONIC SIGNATURES
I, Gregory Mauro, attest that all other signatories to this document, on whose behalf this
filing is submitted, concur in the filing’s content and have authorized this filing. I declare under
penalty of perjury, under the laws of the State of California, that the foregoing is true and correct.
____________________________
Gregory Mauro
CERTIFICATE OF SERVICE
I hereby certify that on October 14, 2026, I electronically filed the foregoing with the Clerk
of the Court for the U.S. District Court, for the Eastern District of California using the CM/ECF
system. All participants are registered CM/ECF users, and will be served by the CM/ECF system.
Dated: October 14, 2026 	/s/ James R. Hawkins
James R. Hawkins, Esq.
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JOINT STIPULATION TO CONTINUE MOTION TO COMPEL ARBITRATION AND RELATED DEADLINES
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ORDER GRANTING JOINT STIPULATION TO CONTINUE
MOTION TO COMPEL ARBITRATION DEADLINES
Having considered the Parties’ Joint Stipulation to Continue Discovery and Related Pretrial
Deadlines, and good cause appearing therefor, the Court hereby GRANTS the Parties’ request.
The deadlines relating to Defendant’s Motion to Compel Arbitration are modified as follows:
1. 	Plaintiff’s deadline to file his Opposition to Defendant’s Motion to Compel
Arbitration is continued from October 16, 2026 to May 12, 2027.
2. 	Defendant’s deadline to file its Reply in support of its Motion to Compel Arbitration
is continued from October 23, 2026 to May 19, 2027.
IT IS SO ORDERED.
DATED: October 15, 2026
____________________________
Troy L. Nunley
Chief United States District Judge
Case 2:25-cv-02862-TLN-JDP Document 29 Filed 10/15/26 Page 5 of 5