Filed: Apr. 15, 2019
Latest Update: Apr. 15, 2019
Summary: STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED NOTICE AND CONSENT-TO-SUE FORMS GLORIA M. NAVARRO , Chief District Judge . RECITALS On September 21, 2016, Plaintiffs MAUREEN CLARK and SONYA ALEXANDER ("Plaintiffs") filed a putative class and collective action complaint in the United States District Court, District of Nevada (Dkt. #1); On June 22, 2018, Plaintiffs filed their Second Amended Class and Collective Complaint (Dkt. #52); On March 31, 2019, the Court granted Plain
Summary: STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED NOTICE AND CONSENT-TO-SUE FORMS GLORIA M. NAVARRO , Chief District Judge . RECITALS On September 21, 2016, Plaintiffs MAUREEN CLARK and SONYA ALEXANDER ("Plaintiffs") filed a putative class and collective action complaint in the United States District Court, District of Nevada (Dkt. #1); On June 22, 2018, Plaintiffs filed their Second Amended Class and Collective Complaint (Dkt. #52); On March 31, 2019, the Court granted Plaint..
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STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED NOTICE AND CONSENT-TO-SUE FORMS
GLORIA M. NAVARRO, Chief District Judge.
RECITALS
On September 21, 2016, Plaintiffs MAUREEN CLARK and SONYA ALEXANDER ("Plaintiffs") filed a putative class and collective action complaint in the United States District Court, District of Nevada (Dkt. #1);
On June 22, 2018, Plaintiffs filed their Second Amended Class and Collective Complaint (Dkt. #52);
On March 31, 2019, the Court granted Plaintiffs' Pre-Discovery Motion for Conditional Certification Pursuant to 29 U.S.C. § 216(b) and ordered the parties to meet and confer to correct certain deficiencies the Court identified in Plaintiffs' proposed notice to putative collective members, and to resubmit the proposed notice and consent-to-sue forms for the Court's approval within fourteen days, which falls on the pressent date of April 15, 2019 (Dkt. #65);
The Parties have met and conferred to prepare revised proposed notice and consent-to-sue forms, but have not yet agreed upon final versions for submission to the Court. The Parties are confident that if given seven (7) more days to confer, they will reach an agreement on revised documents to file for the Court's aproval;
STIPULATION
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs and Defendant, through their respective undersigned counsel of record, that:
1. The Parties will have until April 22, 2019 to resubmit the proposed notice and consent-to-sue forms for the Court's approval, an extension of 7 days;
IT IS SO STIPULATED.
DATED: April 15, 2019 WOLF, RIFKIN, SHAPIRO, SCHULMAN &
RABKIN, LLP
By: /s/Don Springmeyer
Don Springmeyer, Esq.
Attorneys for Plaintiffs
MAUREEN CLARK and SONYA
ALEXANDER
DATED: April 15, 2019 MCGUIREWOODS LLP
By: /s John Van Hook
Michael D. Mandel, Esq.
John A. Van Hook, Esq.
Attorneys for Defendant
BANK OF AMERICA, N.A.
[PROPOSED] ORDER GRANTING STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED NOTICE AND CONSENT-TO-SUE FORMS
[PROPOSED] ORDER
Based on the Stipulation of the Parties and good cause appearing, the Court hereby GRANTS the Parties' Stipulation to Extent Time to Re-submit Proposed Notice and Consent-to-Sue Forms, and Orders as follows:
1. The Parties will have until April 22, 2019 to resubmit the proposed notice and consent-to-sue forms for the Court's approval, an extension of 7 days;
IT IS SO ORDERED.
