Filed: Dec. 05, 2019
Latest Update: Dec. 05, 2019
Summary: STIPULATION FOR BRIEFING SCHEDULE REGARDING DEFENDANT'S OBJECTIONS TO PLAINTIFF'S AMENDED PROPOSED OPT-IN NOTICE AND AMENDED PROPOSED CONSENT FORM (ECF NO. 64) JAMES C. MAHAN , District Judge . STIPULATION Plaintiff Devonte' Reese, by and through his counsel of record, and Defendant NPSG Global, LLC, by and through its counsel of record, hereby submit this stipulation to set a briefing schedule regarding Defendant's Objections to Plaintiff's Amended Proposed Opt-In Notice and Amended Propo
Summary: STIPULATION FOR BRIEFING SCHEDULE REGARDING DEFENDANT'S OBJECTIONS TO PLAINTIFF'S AMENDED PROPOSED OPT-IN NOTICE AND AMENDED PROPOSED CONSENT FORM (ECF NO. 64) JAMES C. MAHAN , District Judge . STIPULATION Plaintiff Devonte' Reese, by and through his counsel of record, and Defendant NPSG Global, LLC, by and through its counsel of record, hereby submit this stipulation to set a briefing schedule regarding Defendant's Objections to Plaintiff's Amended Proposed Opt-In Notice and Amended Propos..
More
STIPULATION FOR BRIEFING SCHEDULE REGARDING DEFENDANT'S OBJECTIONS TO PLAINTIFF'S AMENDED PROPOSED OPT-IN NOTICE AND AMENDED PROPOSED CONSENT FORM (ECF NO. 64)
JAMES C. MAHAN, District Judge.
STIPULATION
Plaintiff Devonte' Reese, by and through his counsel of record, and Defendant NPSG Global, LLC, by and through its counsel of record, hereby submit this stipulation to set a briefing schedule regarding Defendant's Objections to Plaintiff's Amended Proposed Opt-In Notice and Amended Proposed Consent Form (ECF No. 64).
The Court entered its Order granting Plaintiff's motion for conditional certification and approval of Hoffman-Laroche notice on November 14, 2019 (ECF No. 63). The Order included a deadline that ordered Defendant to file written objections, if any, to Plaintiff's proposed notice and opt-in forms on December 3, 2019. Defendant timely filed its objections on December 3, 2019 (ECF No. 64). Plaintiff requests an opportunity to respond to Defendant's objections.
After discussion regarding respective schedules around the impending holidays, the parties agreed that it would be appropriate to stipulate a briefing schedule allowing Plaintiff to respond to the objections, and for Defendant to thereafter file a reply. The parties hereby stipulate to a deadline of December 23, 2019 for Plaintiff to file his Response to Defendant's Objections to Plaintiff's Amended Proposed Opt-In Notice and Amended Proposed Consent Form. Further, the parties agree that Defendant's deadline to file its Reply shall be January 9, 2020.
The parties submit this stipulation and ask that the Court approve their proposed briefing schedule, permitting Plaintiff to file a Response to Defendant's Objections by December 23, 2019, and permitting Defendant to file its Reply by January 9, 2020.
DATED this 5th day of December, 2019.
Respectfully submitted,
HKM EMPLOYMENT ATTORNEYS LLP JACKSON LEWIS P.C.
/s/Jenny L. Foley /s/Daniel I. Aquino
Jenny L. Foley, Ph.D., Esq., Bar No 9017 Kirsten A. Milton, Bar No. 14401
Marta D. Kurshumova, Esq., Bar No. 14728 Daniel I. Aquino, Bar No. 12682
1785 East Sahara, Suite 300 300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89104 Las Vegas, NV 89101
/s/Jason A. Rittereiser Attorneys for Defendants
Jason A. Rittereiser, (pro hac vice)
Rachel M. Emens, (pro hac vice)
Henry Brudney, (pro hac vice)
600 Stewart Street, Suite 901
Seattle, WA 98101
STUTHEIT KALIN LLC
/s/Kyann Kalin
Kyann Kalin, (pro hac vice)
1 SW Columbia Street, Suite 1850
Portland, OR 97204
Attorneys for Plaintiff
IT IS SO ORDERED.
