Filed: Jun. 01, 2015
Latest Update: Jun. 01, 2015
Summary: STIPULATION AND PROPOSED ORDER RE BRIEFING AND HEARING SCHEDULE ON PLAINTIFFS' MOTION FOR LEAVE TO FILE PLAINTIFFS' FIRST AMENDED COMPLAINT EDWARD M. CHEN , District Judge . This stipulation is entered into by and between Plaintiffs William Woods, Dominic Seale, Wesley Varughese, Eric Essler, and Samuel Barone-Crowell ("Plaintiffs") and Defendant Vector Marketing Corporation ("Defendant," or collectively with Plaintiffs, the "Parties") by and through their counsel of record, with reference
Summary: STIPULATION AND PROPOSED ORDER RE BRIEFING AND HEARING SCHEDULE ON PLAINTIFFS' MOTION FOR LEAVE TO FILE PLAINTIFFS' FIRST AMENDED COMPLAINT EDWARD M. CHEN , District Judge . This stipulation is entered into by and between Plaintiffs William Woods, Dominic Seale, Wesley Varughese, Eric Essler, and Samuel Barone-Crowell ("Plaintiffs") and Defendant Vector Marketing Corporation ("Defendant," or collectively with Plaintiffs, the "Parties") by and through their counsel of record, with reference t..
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STIPULATION AND PROPOSED ORDER RE BRIEFING AND HEARING SCHEDULE ON PLAINTIFFS' MOTION FOR LEAVE TO FILE PLAINTIFFS' FIRST AMENDED COMPLAINT
EDWARD M. CHEN, District Judge.
This stipulation is entered into by and between Plaintiffs William Woods, Dominic Seale, Wesley Varughese, Eric Essler, and Samuel Barone-Crowell ("Plaintiffs") and Defendant Vector Marketing Corporation ("Defendant," or collectively with Plaintiffs, the "Parties") by and through their counsel of record, with reference to the following facts:
A. On or about January 16, 2014, Plaintiffs filed their Class and Collective Action Complaint ("Complaint") in the above-captioned action;
B. On or about May 22, 2015, this Court issued its Order Granting In Part and Denying in Part Defendant's Motion for Partial Summary Judgment. (Doc. 164). In its Order this Court held that proposed representative plaintiff for the Missouri Class, Casey McCaleb's claim for unpaid wages under the Missouri Minimum Wage Act was time barred. This court further stated that Plaintiffs may bring a Rule 15 motion to amend to add a new plaintiff and that Plaintiffs may seek leave to bring their Rule 15 motion on an expedited basis. (Order at p. 12).
C. The Parties have agreed to the following briefing and hearing schedule:
• May 29, 2015 — Plaintiffs submit Motion to Amend Complaint to Add a Party Pursuant to FRCP 15(a)
• June 5, 2015 — Defendant submits Opposition to Plaintiff's Motion to Amend Complaint to Add a Party Pursuant to FRCP 15(a)
• June 8, 2015 — Plaintiffs submit Reply
• June 11, 2015 — Proposed Hearing Date; or parties will agree to submit on the papers at the Court's discretion.
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties, through their respective counsel of record and subject to this Courts approval, that Plaintiffs will submit their Motion to Amend on May 29, 2015; Defendant will submit its Opposition to Plaintiffs' Motion on June 5, 2015; Plaintiffs will submit their Reply on June 8, 2015 and the hearing on Plaintiffs' Motion will be held on June 11, 2015, or submit based on the papers at the Court's discretion.
This Stipulation is without prejudice to any of Defendant's defenses or other rights in this action, including (without limitation) the right to oppose the motion to amend.
SO STIPULATED.
[Proposed] ORDER
Good cause appearing, the Parties' Stipulated Briefing and Hearing Schedule set forth above is hereby approved and made an Order of the Court.
IT IS SO ORDERED.
