STIPULATION AND REQUEST FOR EXTENSION OF TIME TO RESPOND PLAINTIFFS' MOTION FOR CLASS CERTIFICATION (Docket No. 23)

(First Request)

GLORIA M. NAVARRO, District Judge.

Pursuant to Local Rule 6-1, the undersigned parties stipulate and request that the Court grant a ten (10) day extension of the time for Defendant Southern Nevada T.B.A. Co. d/b/a Ted Wiens Tire & Auto Centers ("Ted Wiens") to respond to Plaintiffs' Motion for Class Certification (Docket No. 23). The requested extension would move the reply deadline from April 22, 2016 to May 2, 2016. In support of this Stipulation and Request, the parties state as follows:

1. Plaintiffs' filed Plaintiffs' Motion for Class Certification on April 5, 2016.

2. Defendant's response/opposition is due April 22, 2016.

3. On April 15, 2016, Defendant filed an Emergency Motion to Extend Time to Respond to Plaintiffs' Motion to Certify Class Action (Docket No. 27), which by reason of the stipulation is mooted and hereby withdrawn.

4. On April 21, 2016, Plaintiffs' counsel agreed to extend the deadline to respond to the Motion for Class Certification to May 2, 2016.

5. This stipulation and request for the brief extension of time is not sought for any improper purpose or for delay. Rather, it is sought solely to facilitate the parties' consideration, review, discussion, and possible agreement designed to streamline the collective action certification and noticing process for the Fair Labor Standards Act Claim. This includes, but is not limited to, the procedure for noticing the proposed class of the 29 U.S.C. § 216(b) action, including but not limited to the procedures, form and content of the notice, the opt-in period, possible temporary tolling of the statute of limitations, and other relevant issues.

WHEREFORE, the parties respectfully request that this Court extend the date for Ted Wiens to respond to Plaintiffs' Motion for Class Certification from April 22, 2016 up to and including May 2, 2016.

ORDER

IT IS SO ORDERED.